Title 24 Lighting Requirements for Commercial Retrofits

A California lighting retrofit can look straightforward: count the fluorescent fixtures, select LED replacements and calculate the savings. The quote gets harder when you reach the controls, wiring and paperwork.

Title 24 lighting requirements depend on what you are changing and which compliance path applies. A lamp replacement, an LED retrofit kit and a complete fixture replacement can lead to different scope decisions.

Before you price the job, establish five things: the applicable code edition, the alteration scope, the lighting power calculation, the controls scope and who will handle the compliance documents and testing.

This guide focuses on indoor lighting retrofits in existing California commercial buildings, including offices, warehouses and retail spaces.

Which Title 24 Energy Code Applies in 2026?

California’s lighting energy requirements sit within Title 24, Part 6, commonly called the Energy Code. The California Energy Commission’s 2025 Energy Code applies to permit applications submitted on or after January 1, 2026.

The permit application date matters more than the date on your proposal. Record it at the start, along with the project address, permitting jurisdiction and any local requirements your project team identifies.

Keep that information on the job record. A proposal revised months after the first walkthrough should still show which edition the design team used.

When Do Title 24 Lighting Requirements Apply to a Retrofit?

Under Section 141.0(b)2I, the indoor alteration rules generally apply when 10% or more of the luminaires serving an enclosed space are altered, subject to exceptions. Changes to lighting wiring also count as lighting system alterations.

The 2025 Energy Code, Section 141.0 is the starting point for checking the scope.

Do two counts during the audit: all existing fixtures in each enclosed space, and the fixtures you plan to alter. A building-wide total alone will not show the room-level percentage.

Separate Maintenance From Fixture Alterations

Replacing lamps only, or ballasts or drivers only, is different from installing a retrofit kit. The CEC’s indoor lighting compliance manual treats kits replacing lamps and ballasts as luminaire alterations.

Record the actual work: lamp replacement, kit installation, complete fixture replacement, relocation or rewiring. “LED upgrade” is too vague for the person reviewing the scope.

Check the Small-Project Exception

There is an exception for one-for-one alterations of up to 50 luminaires per complete floor or complete tenant space, per year. The 2025 indoor lighting compliance form includes this exception.

Ask about earlier work during the year before relying on it. Fifty fixtures in the current quote may not represent the full annual count. Other exceptions also exist, including enclosed spaces with only one luminaire.

Choose the Lighting Power Path Before Specifying Controls

For alterations covered by Section 141.0(b)2I, there are three prescriptive options:

Option	Lighting power condition
1	Meet the indoor lighting power allowance in Section 140.6.
2	Use no more than 80% of that allowance.
3	Make a one-for-one alteration within a building or tenant space of 5,000 square feet or less, reducing the total wattage of the altered fixtures by at least 40%.

Each option also has controls requirements. The 80% option compares proposed power with the code allowance, not with the old lighting load. The 40% option compares altered fixtures before and after, with the stated size restriction.

Do not apply the 5,000-square-foot limit to just the room you are quoting when the building or tenant space is larger.

Have the project designer identify the path before you finalize the equipment list. That decision can change the control package and installation cost.

Title 24 Lighting Controls: What Belongs in the Quote?

Record existing controls, proposed devices and quantities by room so the estimator and designer can review the same scope.

Table 141.0-F ties controls to the selected alteration option. The CEC manual explains the distinction:

Control function	Option 1	Options 2 and 3
Manual controls	Required	Required
Automatic shutoff	Required	Required, with specified exceptions
Multilevel controls	Required where applicable	Not required by this alteration table
Daylight-responsive controls	Required where applicable	Not required by this alteration table
Demand-responsive controls	Required where applicable	Not required by this alteration table

Room-specific thresholds and exceptions still apply. Existing required control functions must also be preserved. See the CEC’s explanation of alteration controls.

For estimating, work through each room rather than adding a general “sensors included” line. Record which fixtures each sensor or switch will control, the proposed device quantities and any wiring or programming work.

Check compatibility before ordering. A dimmable fixture needs the right driver and control interface. Sensor coverage needs to suit the ceiling height, partitions and use of the room.

Also ask the owner how the space operates. A scheduled office, a warehouse with changing shifts and a storage room visited twice a day present different installation and setup questions.

What to Record During a Commercial Lighting Audit

A useful audit gives the estimator and designer enough detail to work without repeating the walkthrough. Keep the fixture inventory tied to individual spaces.

Audit record	What to capture
Location and use	Floor, room name, space type and how the area is used.
Dimensions	Room area, ceiling height and the total building or tenant area relevant to the proposed path.
Existing fixtures	Type, quantity, lamps, ballast or driver information and supported input wattage.
Proposed work	Lamp, kit or fixture replacement; added or relocated fixtures; wiring changes.
Existing controls	Switches, sensors, timers, dimming systems and the fixtures they serve.
Daylight conditions	Windows, skylights, nearby fixtures and photos for the designer’s review.
Installation conditions	Voltage, accessible panel information, ceiling access, lift needs and working-hour restrictions.
Evidence	Room overview, fixture label, ballast or driver label, existing controls and relevant obstructions.

Give repeated spaces distinct names. “Office” is less useful than “Second Floor, Office 204” when someone needs to locate a photo or resolve a quantity discrepancy.

When a detail cannot be verified, mark it as unknown and assign a follow-up. An assumed wattage or guessed circuit relationship can pass through several spreadsheets before someone notices it.

Keep Connected Watts Separate From Annual Energy Use

Lighting power calculations use watts. Annual energy estimates use kilowatt-hours and operating schedules. Keep both, but label them clearly.

The 2025 NRCC-LTI indoor lighting form asks for fixture quantities, wattage and how the wattage was determined. Its power allowance tables also use space classifications and floor area.

Keep manufacturer cut sheets with the schedule. A lamp’s nominal wattage is not necessarily the full fixture input, particularly with existing fluorescent or discharge systems.

Example: Why a 44% Wattage Reduction Does Not Settle the Code Question

The office row in LumaQuote’s fictional sample proposal replaces 24 fluorescent fixtures rated at 72 watts with 24 LED panels rated at 40 watts.

Office fixture line	Existing	Proposed
Quantity	24	24
Watts per fixture	72 W	40 W
Total connected power	1,728 W	960 W

The reduction is 768 watts, or 44.4%: (1,728 − 960) ÷ 1,728 × 100.

That is useful proposal data. It does not establish the California compliance path. The sample represents a fictional Ohio project and does not provide the office area, total tenant area or the information needed to assess California alteration exceptions.

For a California quote, attach those missing scope details to the fixture comparison. Also identify the selected controls and document responsibility. The customer can then see both the energy improvement and the work included in the price.

You can review the full format in the sample lighting retrofit proposal.

Price the Work Around the Fixtures

Once the scope is established, make the supporting work visible in the estimate. Useful cost lines include:

• Control devices, controllers and accessories.

• Control wiring, circuit changes and installation labor.

• Lift rental, difficult access and work outside normal business hours.

• Programming, sensor adjustments and owner training.

• Design support, compliance documents, permits and required testing.

• Disposal and any agreed patching or ceiling work.

State who supplies each service. If another contractor handles the controls, identify the handoff and who checks compatibility with your fixture selection.

Keep exclusions specific. “Controls by others” should name the responsible party or explain what must be resolved before installation. The same applies to permit fees and testing.

Use the customer’s operating hours and electricity rate for the savings estimate. If controls savings are estimated separately, show the assumptions and avoid counting the same reduction twice.

Plan Title 24 Documents and Acceptance Testing Early

The CEC publishes 2025 nonresidential compliance documents, including:

Document	Purpose
NRCC-LTI	Indoor lighting certificate of compliance.
NRCI-LTI	Indoor lighting certificate of installation.
Applicable NRCA forms	Acceptance records for control functions such as shutoff, daylight response and demand response.

Name the person responsible for each applicable document before the job starts. Keep the fixture schedule, controls schedule and approved design consistent as substitutions occur.

For covered indoor alterations, the acceptance-testing exception applies when added controls serve 20 or fewer luminaires across the entire alteration project. Count the fixtures controlled, not the number of sensors installed.

Where required, lighting controls acceptance testing must be performed by a certified lighting controls acceptance test technician. The CEC explains acceptance testing requirements and the technician certification program.

Schedule testing while the installation team can still make adjustments. Leave time for access, programming corrections and the final paperwork.

How LumaQuote Helps With a California Lighting Retrofit

Export the audit spreadsheet and photos for the team preparing the design, estimate and compliance documents.

LumaQuote helps contractors carry the field inventory into the proposal without rebuilding the room list.

During the iPad audit, you can record space type, square footage, ceiling height, voltage, operating hours, fixture quantities and wattage. Existing controls and proposed controls stay with the space, including device quantities and notes. Photos help the office team review the conditions behind the estimate.

The field app works offline, which is useful in warehouses, basements and other areas with poor reception. Back at the desk, the audit supports replacement selections, installation costs and the customer proposal. See the iPad lighting audit to desktop workflow.

You can also export the audit as CSV, or as a ZIP with the spreadsheet and photos organized by space and fixture. That gives the designer or compliance consultant a usable handoff for their calculations and documents.

LumaQuote organizes the audit and proposal data; the project team prepares and verifies the Title 24 compliance work. Explore the lighting audit software for a closer look at the field workflow.

Questions to Resolve Before Sending the Proposal

Before sending the final price, confirm that the owner, installer and designer agree on:

1. What is being replaced, retained, added or rewired.

2. The selected compliance path and supporting area and wattage records.

3. The controls included in each space.

4. Who handles permits, documents, setup and testing.

5. What happens if site conditions or equipment substitutions change the scope.

Keep exterior fixtures on a separate schedule. Outdoor alterations have their own rules, so the indoor options above should not be carried into a parking lot or wall-pack estimate.