LCC Alert: Public Comment Open on Proposed Building Code Changes Impacting Child Care Programs

Posted By: Valerie Denero News and Updates,

California’s licensed child care community has an important opportunity to weigh in on proposed changes that could impact facility operations, infant care capacity, and the cost of providing care.

The California Building Standards Commission (CBSC) has opened a public comment period through May 18, 2026 on proposed amendments included in the Intervening Supplement to the 2025 California Building Standards Code (Title 24). These changes focus on structural, health, and green building standards and are scheduled to be published January 1, 2027, becoming effective July 1, 2027.

For licensed child care providers, this public comment period is especially important.

Why This Matters for Child Care Providers

Providers across California have raised serious concerns about how recent and proposed code changes may affect the affordability and feasibility of operating child care programs—particularly infant and toddler care.

Key concerns include:

Occupancy Classification Changes
Proposed and recent changes related to Group I-4 versus Group E occupancy classifications continue to raise concerns. Reclassification of some child care settings can trigger more stringent requirements for programs serving more than five infants, with significant implications for facility design and compliance.

Costly Fire Safety Requirements
Mandatory automatic fire sprinkler requirements tied to some classifications may create substantial financial burdens for providers, especially small businesses and nonprofit centers, with upgrades costing hundreds of thousands of dollars.

Reduced Infant Capacity
Some interpretations of current standards have limited infant classroom capacity, contributing to reduced enrollment opportunities for families and worsening California’s infant care shortage.

Operational and Licensing Challenges
Providers have also expressed concern about implementation challenges tied to changing facility standards, communication gaps, and overlapping impacts with Title 22 licensing requirements.

Public Comment Period Details

Comment Deadline: May 18, 2026 (midnight)

Submit Comments:

  • Email: cbsc@dgs.ca.gov

  • Mail: California Building Standards Commission
    Attention: Public Comments
    2525 Natomas Park Drive, Suite 130
    Sacramento, CA 95833

Comments may address proposed amendments to Parts 1, 2, and 10 of the 2025 Title 24 code.

Advocacy in Action

State leaders have taken steps to address concerns through mitigation efforts, including legislation such as Assembly Bill 176 and ongoing work between the Office of the State Fire Marshal (OSFM) and the California Department of Social Services (CDSS) to explore more workable solutions.

Now providers have an opportunity to help shape what comes next.

This public comment period is a critical chance for licensed child care programs to share how proposed building standards could affect operations, enrollment, facilities costs, and access to care in their communities.

We encourage providers to review the proposed changes and submit comments before the deadline. Your voice can help inform practical, workable standards that support both safety and access to care.

Take Action
If these proposed changes would affect your program, now is the time to speak up. Public comment matters—and provider input is essential.