Energy Code Compliance Program

The CEC has adopted the 2025 Energy Code, which is expected to take effect on January 1, 2026. The revised regulations include the Energy Code Compliance (ECC) Program. Until the 2025 Energy Code becomes effective, HERS Program regulations will continue to be enforced.

The ECC Program was developed to continue the field verification and diagnostic testing (FV&DT) provisions given in Title 20 of the California Code of Regulations. Through a rulemaking, the regulations were moved from Title 20 HERS Program regulations into the administrative section of Title 24. Prior FV&DT services will continue without disruption, but there will be changes in program administration, primarily in its identity.

The ECC Program helps a project demonstrate compliance with the Energy Code through testing and documentation. The ECC Program ensures code compliance and the consumer’s expected quality of installation of efficiency measures.

This program will be administered by ECC-Providers, who will train and certify ECC-Raters to determine whether an installed energy efficiency measure meets Energy Code requirements.  

When code compliance requires testing of one or more installed energy measures, the installing contractor and an ECC-Rater will perform field verification and diagnostic testing as specified on the project's certificate of compliance. The results of these tests must be recorded using an ECC-Provider’s residential data registry. If an ECC-Rater determines that a test fails compliance thresholds, the contractor is required to fix the feature or system until it passes compliance. The ECC-Provider ensures that the ECC-raters and ECC-Rater Companies are upholding accurate results.

The accordion menu below addresses an array of questions about the ECC Program and how stakeholders may understand the transition from HERS to ECC.

Program Questions and Answers

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To submit a question about the ECC Program, please email SCO@energy.ca.gov.

  1. Is this a new program?
    1. Yes, but it is also the continuation of the HERS Program, with significant changes. 
      1. "HERS I" or the field verification and diagnostic testing (FV&DT) part of the HERS Program regulations were migrated to the 2025 Energy Code revision, contingent on its effectiveness.
      2. "HERS II" or the whole house rating program has not moved and will remain in the HERS Program and regulations.
  2. How or why did this program come about?
    1. The ECC Program is a singular product of two rulemakings. One rulemaking amended the HERS regulations while the other rulemaking ensured that the provisions would not only continue, but that the regulations would reside under the same code that they were intended to support. The original regulations were too-infrequently updated to meet the needs of the triennial Energy Code. Because of this and for other reasons a new program was needed to focus on ensuring compliance and to be distinguished from optional home energy rating and labeling services.
  3. When does this program begin?
    1. The ECC Program becomes effective with the 2025 Energy Code, which is expected to take effect on January 1, 2026.
  4. When is participation required?
    1. As with the HERS program under previous iterations of the Energy Code, when the scope of the project includes features that must be tested to qualify its Energy Code compliance. 
  5. Who will enforce these requirements?
    1. State regulations like the Building Code are enforced by local (i.e., city and county-level) agencies such as building or planning departments. The Energy Code refers to these agencies as Authorities Having Jurisdiction. Residential enforcement will continue as usual. The primary difference is in the naming of the program, which will appear on the data registries and on the 2025 compliance documents.
    2. ECC-verification is part of the permit process. A qualifying application for a permit should include a registered certificate of compliance. There is an exception for urgent alterations (e.g., HVAC changeouts) that allows the certificates to be registered later, but before the permit is closed or finalized.
  6. Who administers the program?
    1. ECC-Providers. ECC-Providers are approved by the CEC to train ECC-Raters (and ECC-Rater Companies), oversee the quality of their raters' work, and to operating a residential data registry. Compliance and enforcement are facilitated through the registry, where compliance forms are completed by installers and raters, and retained for submission to building departments.
      1. To obtain copies of a project's documentation, one must coordinate with the builder, installing contractor, rater, or anyone that had a role in the compliance forms process. 
      2. Title 24 requires that completed documentation must be left in the home for the building owner. It also requires that an ECC-Provider send certificates of verification to the homeowner if that person's contact information is available on the registry.
      3. The CEC does not offer document registration and does not retain compliance documents for public access.
    2. The CEC will list approved ECC-Providers on a separate web page (pending publication) to give details about the scope of approval and contact information.
    3. HERS providers that were approved to administer the FV&DT program under the 2022 Energy Code may continue to oversee raters and operate a data registry but must be re-approved for the 2025 code cycle as ECC-Providers.
  7. How do I ask a question that is not covered on this page?
    1. The ECC Program is overseen by the Standards Compliance Branch in support of the Building Energy Efficiency Standards program. 
      1. To email an inquiry, contact SCO@energy.ca.gov. 
      2. Additional information is available through the Energy Code Support Center.
      3. Subscribe to Energy Efficiency Topics>Building Energy Efficiency Standards via govDelivery for updates and announcements. updates and announcements.
  1. How will the compliance software and forms be affected?
    1. On 2025-based compliance documents and tools, any references to HERS will be replaced with either ECC or FV&DT, depending on context.
  2.  What happens to my 2016/2019/2022-compliant project when 2025 goes into effect?
    1. The process is mostly unaffected for designers, consultants, builders, and installing contractors.
    2. The most apparent change will be the replacement of all "HERS" terminology, but only for 2025 Energy Code-based software and forms.
    3. Program changes that will affect installers and builders:
      1. Group Sampling for alterations projects has been removed in the Reference Appendices (RA2.8), which affects prior-cycle projects.
      2. Refrigerant charge verification (RCV) weigh-in methods (RA3.2.3) have been revised. 
      3. Fault indicator displays (FID) alone may not be used by the installer or rater to demonstrate RCV compliance.
  3. On the certificate of compliance, how will readers identify the measures that require FV&DT? 
    Previously this was called the HERS FEATURE SUMMARY. Note that a final title is yet to be decided. Possible titles:
    1. ECC FEATURES SUMMARY 
    2. Field Verification and Diagnostic Testing Summary
    3. Measures To Be Tested for Compliance
    4. Measures to be ECC-Verified
    5. Testing and Verification Protocols Required
    6. Required Field Verification and Diagnostic Testing
  1. Do I need to renew my rater-provider agreement?
    1. Yes, as the regulations regarding these agreements have changed in name and in content.
  2. Before I update to 2025 certification, am I a HERS rater or an ECC Rater?
    1. Because the Title 20 HERS regulations will no longer apply, all HERS raters will be known as ECC-Raters. Active certifications will remain intact. A 2022-Energy Code HERS rater will be a 2022 Energy Code ECC-Rater. 
  3. Can raters and rating companies keep "HERS" in their business names and listing of services?
    1. Yes. Rulemaking feedback indicated that mandated renaming would be burdensome. Businesses should consider rebranding ahead of the 2028 Energy Code.
    2. The CEC does not regulate business entity names. However, the CEC does regulate providers and will recognize these entities as ECC-Providers that need to be re-approved to administer the ECC Program under the 2025 Energy Code.
  4. Should raters and rater companies add the new program name to their signage, publications, business listings, and web pages?
    1. Yes, although it could be beneficial to present dual terminology where feasible, such as when replacing printed materials or updating web presence. Compliance documents from earlier code cycles will continue to use the HERS program terminology
    2. Entities should be specific about the certifications each rater holds (e.g., 2022 HERS rater, 2025 ECC-Rater).
  5. Can an ECC-Rater support financing and incentive programs that relied on a HERS rater?
    1. Staff has not explored this question but would like to supply a useful answer.
  1. Will building departments be aware of these changes?
    1. Staff will communicate with local agencies through regular engagement events and through focused correspondence.
    2. Staff may communicate changes in enforcement through advisories and the  Blueprint newsletter.
    3. Other organizations have started communicating the changes to various stakeholders, apart from the CEC.
  2. What happens to my 2016/2019/2022-compliant project when the 2025 Energy Code goes into effect?
    1. The process is the same as far as Energy Code compliance is concerned.
    2. Administratively, some changes will be implemented outside of any project's permit process. These pertain to rater training and discipline, rater company duties, and provider responsibilities.
  3. Are the changes retroactive when demonstrating compliance under a previous Energy Code version?
    1. No. Similar to previous code revisions, the version of code that was effective when the project was permitted remains the applicable version. For example, a 2022-compliant project must be rated to 2022 standards by someone with a 2022 (or later) certification.
  1. What happened to the Title 20 HERS regulations?
    1. These were amended. The significant changes take effect alongside the 2025 Energy Code, expected January 1, 2026. 
    2. This amendment is absent of the FV&DT (HERS I) provisions.
    3. The scope of the regulations has been revised.
    4. HERS Providers must recertify or else they will be decertified. This is supported by section 1674(f), "The Energy Commission may also require that Providers and Rating Systems be re-certified if the requirements of these regulations are amended or modified." In early 2025, staff will publish guidance for a provider to apply to be approved as an ECC-Provider. The CEC has not yet defined a pathway to HERS provider certification under the amended regulations.
  2. Do active providers and raters need to be fully recertified for the 2025 revision?
    1. Under Title 20 regulations, revised rating systems warrant recertification by the Energy Commission.
    2. "Update training" offered by the providers must include the changes to the program, including requirements previously given in Title 20 then relocated to Title 24.
    3. If a provider does not recertify under the new regulations, it will be recognized as an ECC-Provider but only for projects under the 2022 Energy Code and any other past data registry approvals. Staff will be compelled to notify the ECC-Provider that it is out of compliance with program regulations of 10-103.3.
    4. If a rater does not recertify for 2025, then the rater will be recognized as an ECC-Rater. To perform 2025 Energy Code FV&DT, the rater must complete a 2025-certification process (update or new rater) training from an approved ECC-Provider.
    5. Until the 2025 effective date, the application process given in Title 20 will be enforced. Staff will give guidance about how to show compliance with the new regulations using the eminent application requirements.

Contact

Standards Compliance Branch
SCO@energy.ca.gov

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