Certificate of Occupancy vs Certificate of Completion

The International Building Code (IBC) covers this in Section 111. Section 111.1 says no building or structure may be occupied, and no change in the existing use or occupancy classification may be made, until the building official has issued a certificate of occupancy. The exception is work that is exempt from permits under Section 105.2. Section titles shift between editions and local amendments, so confirm the wording in the edition your jurisdiction adopted.

Section 111.2 lists what the certificate must say. The items include the type of construction, the design occupant load, whether the building has a required sprinkler system, and any special stipulations of the permit.

Section 111.4 lets the official suspend or revoke a CO or a temporary CO if it was issued in error or on incorrect information.

Some jurisdictions need a document for the close of a permit that doesn't change what the building is used for. They issue a certificate of completion. Three examples from published city guidance show the pattern, and also the differences.

The pattern is the same in all three: the CO follows new occupancy, and the CC follows work on a building whose classification stays put. After that the cities part ways.

Los Angeles is the clearest about why the CC exists. The LADBS bulletin says the Los Angeles Municipal Code (Section 91.109.1) doesn't require a CO when occupancy doesn't change. Customers had long expected a CO anyway, so the department created the CC to give them paperwork. If part of an apartment building changes occupancy, such as converting a garage, LADBS still issues a CO. The bulletin is labeled P/BC 2020-108, and LADBS also lists it as IB/P/BC 2023-108, so check ladbs.org for the current version.

Local rules can sit further apart than these three, so read your own city's handout rather than assuming it works like Miami's or Los Angeles's.

You can't settle this from the model code, so settle it from the permit. Work through these in order:

1. Check the permit type and the occupancy classification on the approved plans. New building, addition or change of use points to a CO.
2. Check the local handout. Search the building department's site for "certificate of completion." Miami's page, for instance, says your permit application in its iBuild system indicates whether a CO or CC applies.
3. Ask when the finals are scheduled. The building official, not the architect, decides which certificate closes the permit. A short email before the final inspection avoids a surprise at the end.
4. For a shell building, plan for two documents. In Miami and Goose Creek a shell gets a CC. The tenant's finish-out later gets its own permit and, depending on the city, its own CO or CC.
5. For small work, expect neither. Replacing a water heater or a reroof usually ends with a final inspection on the permit and no new certificate.

A passed final inspection is a step in the permit process. The certificate is a separate document that usually follows it. Some cities issue the certificate only after every trade has finalized. Miami's page says the permit must be final first, all final inspections must be approved, and outstanding permit revisions, such as a contractor change, must be resolved. Miami Beach adds a request form and a fee: the sequence is final building inspection, CO/CC request form, invoice and payment, then the Building Official signs.

Some jurisdictions don't issue a paper certificate at all for smaller jobs. They record the approval as a "final" status on the permit. Don't assume your client has a document until you have seen it.

Check the occupancy rule before the move-in date is promised. Some cities say a structure can't be occupied until all final inspections are approved and the certificate is issued. For commercial space, tenants should hold their fixturing and move-in until the certificate is in hand.

When the work isn't done but part of the building is safe to use, the code allows a temporary CO. Under IBC 111.3 the building official may issue one before the entire work is complete, provided the portion to be occupied can be occupied safely. The official sets the period the temporary certificate is valid. Some local codes cap it: Massachusetts's amendment (780 CMR 111.3) says not to exceed 180 days, and Larimer County, CO issues TCOs valid for 180 days.

Cities that use CCs often have a matching temporary certificate of completion (TCC). Miami, Doral and Miami Beach each publish a TCO/TCC process.

City checklists agree on three things:

• Life safety comes first. Tracy, CA lists emergency lighting, exit signs, fire alarms, sprinklers and egress paths as items that must pass before a TCO is approved. Pompano Beach, FL wants life safety systems installed and fully operational before it will take the application.
• Fire and building both sign off. Milpitas, CA requires final inspections from the Fire and Building departments confirming the minimum fire and life safety requirements for temporary occupancy.
• The clock matters. Monroe County, FL requires all finals to pass before the date on the TCO. Santa Clara, CA requires occupants to vacate by the expiration date unless an extension is granted. Winter Park, FL notes that missing the date can lead to termination of electrical service.

Miami adds that TCO/TCC inspections differ from final inspections, and you must get a TCO/TCC inspection for each trade that will need a final. Plan the trade-by-trade schedule backward from the expiration date. If you can't finish in time, ask for an extension before the date, not after. Miami-Dade and Pompano Beach both describe an extension request.

Contract documents add a third certificate. On AIA contracts, the architect prepares a Certificate of Substantial Completion (AIA G704). It sets the date of substantial completion and the owner's and contractor's responsibilities for security, maintenance, heat, utilities, damage and insurance. It is a contract milestone between the owner and contractor.

The CO is a permit document issued by the authority having jurisdiction. They are separate. The contract may connect them. Some contracts make the G704 a condition before the contractor may request a CO or TCO, and others say nothing. Read the contract language before assuming either way. If it doesn't tie the two, the G704 can be issued without a CO, but the building still can't lawfully be occupied without one.

Your closeout package usually collects the G704, final inspection reports, as-builts, O&M manuals, warranties, lien waivers and the final application for payment. Keep a dated list of which certificate each permit needs and who holds it. Olumba's permit tracking can hold those dates.

Requirements differ, but these items come up in the checklists above:

• Approved plans and any revisions on site, with permit revisions resolved
• Fire department final or temporary release where a completion hold exists
• Final inspection sign-offs for each trade on the permit
• The CO/CC request form and fee, where the city has one
• A written request for a temporary certificate, with the occupied area marked, if you need one

For city-specific processes, see our building permit pages by jurisdiction, or read how to get a building permit for the full sequence.