Nonresidential Title 24 Compliance & Verification

What “nonresidential Title 24” means

Title 24 is shorthand for California's Building Energy Efficiency Standards — Title 24, Part 6 of the California Code of Regulations. Most contractors first meet it on houses, where compliance runs on the CF1R (Certificate of Compliance), CF2R (Certificate of Installation), and CF3R (Certificate of Verification). Commercial work follows the nonresidential chapters of the same code, which cover offices, retail, restaurants, warehouses, hotels and motels, and high-rise multifamily buildings — and the paperwork, the tests, and the people allowed to sign them are all different.

The code edition matters too. The 2025 Building Energy Efficiency Standards took effect January 1, 2026, and the permit date decides which code your project is on: per the California Energy Commission (CEC), buildings whose permit applications are applied for on or after January 1, 2026 must comply with the 2025 Energy Code. Earlier applications stay on the 2022 code.

Instead of one rater signing one CF3R, a nonresidential project moves through four families of compliance documents. Here's the chain, in the order it happens.

NRCC, NRCI, NRCA, NRCV — the document chain

• NRCC — Nonresidential Certificate of Compliance. Prepared at the design stage by your energy consultant or engineer and approved with your plans at plan check. It states how the building will comply and lists every acceptance test and field verification the project will owe before final. Everything below traces back to it.
• NRCI — Nonresidential Certificate of Installation. Signed by the installing contractor, certifying that the equipment and systems that actually went in match what the NRCC promised.
• NRCA — Nonresidential Certificate of Acceptance. Completed by a certified Acceptance Test Technician (ATT) after functional testing of lighting controls and mechanical systems, and submitted to the building inspector.
• NRCV — Nonresidential Certificate of Verification. Completed by a certified HERS / ECC rater after field verification and diagnostic testing — most commonly a duct leakage test — and registered with an approved data registry. This is the document ERE signs and registers.

Two acronyms worth pinning down: HERS (Home Energy Rating System) is the long-standing program under which independent third-party raters field-verify energy measures, and ECC (Energy Code Compliance) is the CEC's new name for that compliance program, effective January 1, 2026 — HERS raters are becoming ECC raters, and NRCVs are registered with an ECC provider. CHEERS, approved by the CEC as an ECC provider and data registry, is the registry ERE uses.

Acceptance testing — lighting controls and mechanical

Acceptance tests are functional tests, defined in the code's Nonresidential Reference Appendix NA7, that prove the building's controls actually do what the plans claim — occupancy sensors shut lights off, daylighting controls dim the fixtures near windows, economizers open when outside air is cool, demand control ventilation responds to CO2. Lighting controls acceptance testing falls under Title 24 section 130.4; mechanical systems acceptance testing falls under section 120.5. Each completed test becomes an NRCA form in your permit file.

Who can run them is regulated. Lighting controls acceptance tests have required a certified lighting controls Acceptance Test Technician since July 2014, and mechanical acceptance tests have required a certified mechanical ATT since April 14, 2021. Technicians are certified through CEC-approved Acceptance Test Technician Certification Providers (ATTCPs), and in practice the ATT is usually the installing contractor's technician or a third-party acceptance testing firm.

Where ERE fits: before your inspector asks, we read the NRCC and tell you exactly which acceptance tests your project owes — so the right technician is lined up and the forms exist when you call for final.

HERS / ECC verification on commercial projects — the NRCV

This is the verification ERE performs directly. The most common nonresidential HERS / ECC measure is duct leakage testing: when a nonresidential duct system is required to be sealed and tested under Title 24 section 120.4, leakage cannot exceed 6 percent of the nominal air handler airflow, confirmed through field verification and diagnostic testing by a certified third-party rater — the same role we play on residential HERS / ECC testing, with a separate nonresidential certification behind it.

In practice this shows up on package-unit changeouts and duct replacements at smaller commercial buildings — strip retail, restaurants, small offices — where the ductwork runs across a roof or through a vented attic. If nearly all of the ducts sit inside conditioned space, the test is often exempt. Send us the permit scope or the NRCC and we'll tell you in plain terms whether you owe it.

ERE has held a NonResidential CHEERS certification since 2018. We run the test, complete the NRCV, and register it with CHEERS with same-day field results — the way we've handled inspections since 2015.

Title 20 vs Title 24 — two different codes

These two get mixed up constantly on commercial jobs, and they are different layers of California law. Title 20 is California's Appliance Efficiency Regulations — product-level rules that decide whether a piece of equipment (a rooftop unit, a water heater, an LED fixture) is efficient enough to be sold or offered for sale in California at all. Manufacturers certify compliant models into the CEC's Modernized Appliance Efficiency Database System (MAEDbS); if a model isn't listed there, it can't legally be sold in the state. Energy Code Ace has a plain-English primer.

Title 24, Part 6 is the Building Energy Efficiency Standards — building-level rules about how that equipment is designed into, installed in, and tested in your specific project. A rooftop unit can be perfectly Title 20-compliant as a product and still leave your building out of Title 24 compliance because the ducts leak or the economizer fails its acceptance test.

The practical division of labor: spec equipment that's listed in MAEDbS — that's Title 20, and it's mostly the manufacturer's and distributor's responsibility — then let us handle the Title 24 side: the verifications, the documents, the registry.

Who needs nonresidential Title 24 compliance

• Tenant improvements (TIs) — most TIs touch lighting, HVAC, or the envelope, and each of those pulls compliance documents into the permit. Lighting-only TIs commonly owe lighting controls NRCAs.
• Commercial HVAC changeouts — rooftop package units and split systems on small commercial buildings, where a duct leakage NRCV is the common trigger.
• New commercial buildings — the full chain: NRCC at plan check, NRCIs from your subs, NRCAs from certified ATTs, NRCVs from a certified HERS / ECC rater.
• Anyone whose commercial permit is stuck at final — missing energy paperwork is one of the most common reasons a permit won't close. We reconstruct what's owed and finish it. See Final Inspections & Closeout.

Frequently asked

What is an NRCC (Nonresidential Certificate of Compliance)?

The NRCC is the Nonresidential Certificate of Compliance — the set of Title 24 energy compliance documents your energy consultant or engineer prepares at the design stage and the building department approves with your plans. It states how the building will comply and lists every acceptance test (NRCA) and field verification (NRCV) the project will owe before final. Everything that happens later in the chain traces back to what the NRCC promised.

Who performs the NRCA acceptance tests?

A certified Acceptance Test Technician (ATT). Lighting controls acceptance tests (Title 24 section 130.4) have required a certified lighting controls ATT since July 2014, and mechanical acceptance tests (section 120.5) have required a certified mechanical ATT since April 14, 2021. ATTs are certified through CEC-approved certification providers (ATTCPs) and are usually the installing contractor's technician or a third-party testing firm. Tell us your scope and we'll identify which acceptance tests your NRCC triggers.

Does my commercial HVAC changeout need a duct leakage test?

Often, yes. When a nonresidential duct system is required to be sealed and tested, Title 24 section 120.4 caps leakage at 6 percent of the nominal air handler airflow, confirmed by a certified HERS / ECC rater who completes and registers the NRCV. The most common exemption is duct location — if nearly all of the ductwork runs inside conditioned space, the test usually isn't triggered. Send us the permit scope or the NRCC and we'll confirm either way.

What is the difference between Title 20 and Title 24?

Title 20 is California's Appliance Efficiency Regulations — product-level rules that decide whether a piece of equipment (an AC unit, a water heater, an LED fixture) is efficient enough to be sold in California at all. Manufacturers certify compliant models into the CEC's MAEDbS database. Title 24, Part 6 is the Building Energy Efficiency Standards — building-level rules covering how that equipment is designed into, installed in, and tested in your specific building. ERE handles the Title 24 side; your job on the Title 20 side is simply to spec equipment that's listed in MAEDbS.

Did the 2025 Energy Code change anything for commercial projects?

The 2025 Building Energy Efficiency Standards took effect January 1, 2026, and apply to projects whose permit applications are submitted on or after that date — earlier applications stay on the 2022 code. The nonresidential document chain (NRCC, NRCI, NRCA, NRCV) carries forward, and as of January 1, 2026 the CEC renamed the HERS program for code compliance to the Energy Code Compliance (ECC) program, so NRCVs are now registered with an ECC provider such as CHEERS.

Can ERE manage the whole nonresidential document chain?

We perform the HERS / ECC field verifications and register the NRCV ourselves, and we keep the rest of the chain straight: we read your NRCC, list which NRCA acceptance tests and NRCI installation certificates the project owes, and make sure everything is signed and on file before you call for final. Our NonResidential CHEERS certification has been on file since 2018. If a permit is already stuck at closeout, see Final Inspections & Closeout.