Key Updates for Building Owners and Project Teams

Philadelphia has announced an important code update that will impact construction projects citywide. Beginning January 1, 2026, the City will adopt the 2021 International Codes, bringing new requirements for building safety, energy performance, and system design.

At Milrose, we help project teams stay ahead of regulatory changes. Below is a clear, easy-to-follow overview of what this transition means and how to plan for it.

When the New Codes Take Effect

Starting January 1, 2026, the City of Philadelphia will begin enforcing the 2021 International Codes for all new construction and renovation projects. These updates stem from statewide changes to the Pennsylvania Uniform Construction Code (UCC).

Codes Included in the 2021 Adoption

Philadelphia will adopt the following code editions (with state and local amendments):

• 2021 International Building Code (IBC)
• 2021 International Existing Building Code (IEBC)
• 2021 International Energy Conservation Code (IECC)
• 2021 International Fire Code (referenced provisions)
• 2021 International Mechanical, Plumbing, and Fuel Gas Codes
• 2021 International Residential Code (IRC)
• 2021 ICC Performance Code

Updated referenced standards include:

• NFPA 70 (2020)
• NFPA 72 (2019)

These changes are intended to improve safety, energy efficiency, and consistency across construction practices.

Important Note on Accessibility Requirements

Due to a previous Commonwealth Court ruling, Philadelphia cannot yet enforce the 2021 accessibility provisions.

Until further notice, accessibility requirements will continue to follow the 2018 International Codes and ICC A117.1-2009.

Permit Filing Timeline: What You Need to Know

Philadelphia is offering a transition period to give project teams flexibility when planning upcoming filings.

Applications Filed Before July 1, 2026

You may choose either the 2018 or 2021 code editions.

• Your selected code must be clearly noted on the permit application or drawings.
• If no code edition is identified, the application will default to the 2018 codes.

Applications Filed On or After July 1, 2026

All permits must comply with the 2021 codes.
This deadline applies to all construction-related permits, including trades.

Additional Considerations for Project Teams

• Permit Amendments: Revisions will be reviewed using the same code edition as the original approved permit.
• Expired Permits: Any permit that expires and is refiled will be reviewed under the 2021 codes.
• Master Permit Approvals: Projects currently approved under the 2018 codes must submit all related permits before July 1, 2026.
• Preliminary Plan Reviews: Variances or determinations received under the 2018 codes remain valid only if the full permit application is submitted before July 1, 2026.

How Milrose Can Support Your Team

A code transition can affect design decisions, project schedules, and filing strategy. Our code and permitting experts can help you:

• Evaluate which code edition is best for your project
• Plan filings around key deadlines
• Navigate code changes and compliance risks
• Streamline the permit submission process

If you have questions about how the 2021 codes may impact your building or upcoming project, our team is here to help you move forward with clarity and confidence.