CA: Energy Code Includes Solar Exceptions for Commercial Projects

The 2025 Energy Code went into effect on January 1, 2026. Throughout the Title 24 rulemaking process, ICSC and California Business Properties Association (CBPA) worked to ensure that non-residential solar requirements accurately reflect how commercial buildings are designed and operated. Because of this advocacy, several important reduction and exemption pathways were preserved in Section 140.10(a).

Under the updated standards, a solar PV system is not required if any of the following apply:

• The available Solar Access Roof Area is less than 3% of the building’s conditioned floor area;
• The calculated minimum system size is under 4 kWdc;
• The building has fewer than 80 square feet of contiguous usable roof space; or
• Structural or load‑bearing limitations prevent compliance under ASCE 7 requirements.

Additionally, the revised Exception 5 excludes certain small, independently metered multi‑tenant spaces—2,000 square feet or less with separate HVAC and utility metering—from the PV capacity calculation for nonresidential and hotel/motel buildings. This change helps ensure that properly modeled commercial projects, especially multi‑tenant retail, do not trigger unnecessarily large system sizes.

ICSC and CBPA will continue working to support consistent, practical implementation of the new code.