What Changed? Your Simple Guide to the 2025 California Building Code Chapter 11A
- Corey Taylor
- 1 day ago
- 5 min read
Effective January 1, 2026
If you're building or managing multifamily residential housing in California, there's an important update you need to know about. The 2025 California Building Code Chapter 11A includes a significant scoping change that became effective on January 1, 2026.
This guide explains exactly what changed from 2022 to 2025 in simple, easy-to-understand language.
Complete List of 2025 11A CBC Section Changes
Here's the official list of sections that changed from 2022 to 2025 for Chapter 11A:
Sections with Scoping Changes
Section 1101A.1 Scope
Section 1102A.1 Where required
When Does This Apply?
January 1, 2026 is the key date.
Any building permit application submitted on or after January 1, 2026 must comply with the 2025 code. If you submitted your application before the end of 2025, you're still under the 2022 code.
The One Major Change: Public Housing Removed from Chapter 11A
Sections 1101A.1 (Scope) and 1102A.1 (Where Required)
What changed: Removed Chapter 11A from the requirements for newly constructed covered multifamily dwellings which can also be defined as public housing. These occupancies shall continue to be subject to the requirements of Chapter 11B.
Translation: If you're building multifamily housing that qualifies as public housing (housing owned, operated, or constructed by, for, or on behalf of a public entity), you no longer use Chapter 11A. These projects are now governed solely by Chapter 11B.
Understanding What This Means
What is Public Housing?
Public housing means housing facilities owned, operated, or constructed by, for, or on behalf of a public entity.
Examples include:
Housing owned by a housing authority
Housing operated by a city, county, or state agency
Housing constructed with public funding for a government entity
Affordable housing projects developed by or for public agencies
What is Chapter 11A?
Chapter 11A is the Housing Accessibility chapter of the California Building Code. It provides accessibility requirements for:
Covered multifamily dwellings (apartments and condos)
Private residential buildings with 3+ units (if they have an elevator)
Private residential buildings with 4+ units (ground floor units if no elevator)
Chapter 11A is based on the federal Fair Housing Act requirements and provides "adaptable" features rather than full accessibility.
What is Chapter 11B?
Chapter 11B is Accessibility to Public Buildings, Public Accommodations, Commercial Buildings, and Public Housing. It provides more stringent accessibility requirements than Chapter 11A, including both adaptable features and mobility features.
Why This Change Matters
Before 2025 (Historical Context)
Important clarification: Public housing actually moved from Chapter 11A to Chapter 11B back in the 2019 code cycle(effective July 2021), not in the 2025 cycle.
The 2025 change to Sections 1101A.1 and 1102A.1 confirms and clarifies that public housing is no longer covered by Chapter 11A.
After 2025
Now: Newly constructed multifamily dwellings that qualify as public housing are governed solely by Chapter 11B.
Result: This eliminates any remaining confusion about whether public housing projects need to comply with both Chapter 11A and Chapter 11B.
What You Need to Do
For Public Housing Projects
If you're working on public housing (owned, operated, or constructed by a public entity):
✓ Use Chapter 11B only for accessibility requirements
✓ Do NOT use Chapter 11A for these projects
✓ Follow the more stringent Chapter 11B requirements for:
Residential dwelling units with mobility features
Residential dwelling units with adaptable features
Public and common areas
Accessible routes
Parking and passenger loading zones
For Private Multifamily Housing
If you're working on private multifamily housing (NOT public housing):
✓ Continue to use Chapter 11A for covered multifamily dwellings
✓ Chapter 11A still applies to:
Private apartment buildings with 3+ units and an elevator
Private apartment buildings with 4+ units (ground floor units if no elevator)
Private condominium buildings with 3+ units and an elevator
Private condominium buildings with 4+ units (ground floor units if no elevator)
How to Determine Which Chapter Applies to Your Project
Step 1: Is it Public Housing?
Ask: Is the housing owned, operated, or constructed by, for, or on behalf of a public entity?
YES → Use Chapter 11B only
NO → Go to Step 2
Step 2: Is it Covered Multifamily Housing?
Ask: Does the building have:
4 or more dwelling units with an elevator? OR
4 or more dwelling units without an elevator (ground floor units only)?
YES → Use Chapter 11A
NO → Not covered by accessibility requirements (or may have limited requirements)
Step 3: Are There Public or Common Areas?
Note: Even if your project uses Chapter 11A for dwelling units, any public or common areas (lobbies, mailrooms, laundry facilities, recreation rooms, parking, etc.) must also comply with Chapter 11B.
Summary of Chapter 11A vs. Chapter 11B for Housing
11A (Private Housing) | Chapter 11B (Public Housing) | |
Applies to | Private multifamily dwellings | Public housing facilities |
Based on | Fair Housing Act | ADA + California requirements |
Requirements | Adaptable features | Mobility features + Adaptable features |
Stringency | Less stringent | More stringent |
Common areas | Must also comply with 11B | Chapter 11B applies |
New in 2025 | Public housing removed from scope | Public housing remains here |
Practical Implications
For Developers
Public housing developers:
Budget for Chapter 11B compliance (generally more costly than 11A)
Plan for both mobility-feature units and adaptable-feature units
Ensure design teams are familiar with Chapter 11B requirements
Private multifamily developers:
Continue using Chapter 11A for dwelling units
Remember common areas still require Chapter 11B compliance
No change to your process
For Architects and Designers
Clearly identify whether a project is public housing at the beginning of design
Use the correct chapter from the start to avoid costly redesigns
Don't assume both chapters apply to the same project
For Plan Reviewers and Building Officials
Confirm project type (public vs. private housing) during plan check
Verify designers are using the correct chapter
Flag any projects incorrectly applying Chapter 11A to public housing
For Property Owners and Managers
Understand which accessibility standard your building was designed to
Keep documentation showing compliance with the applicable chapter
If you're altering an existing public housing project, use Chapter 11B for any accessibility-related alterations
Where to Find Official Information
Department of Housing and Community Development (HCD):
Chapter 11A information: https://www.hcd.ca.gov/building-standards
California Building Standards Commission:
The Bottom Line
The 2025 California Building Code Chapter 11A update became effective January 1, 2026.
The single key change:
Sections 1101A.1 and 1102A.1: Removed Chapter 11A from the requirements for newly constructed covered multifamily dwellings which can also be defined as public housing. These occupancies shall continue to be subject to the requirements of Chapter 11B.
What this means for you:
✓ Public housing (owned, operated, or constructed by public entities) → Chapter 11B ONLY
✓ Private multifamily housing (apartments, condos) → Chapter 11A for dwelling units + Chapter 11B for common areas
✓ This change eliminates confusion and ensures public housing is governed solely by the more stringent Chapter 11B standards
Make sure you correctly identify your project type and apply the right chapter for any permit applications submitted after January 1, 2026.
DISCLAIMER: The information provided in this post is for informational purposes only and does not constitute legal advice. Please consult a qualified attorney or consultant for advice tailored to your situation.
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