Replacing a Roof in California: Permits, Energy Code and License Rules

The permit rule for the same reroof differs by city. San José requires a permit once 25 percent of the roof is redone in 12 months.¹ San Diego requires none if the roof structure is not altered.² The license rule is the same statewide: roofing is C-39 work, and a C-39 license must carry workers' comp even with no employees.^9,10

Building Permit: Set City by City

Roofing work is governed by Chapter 15 of the California Building Code and Chapter 9 of the California Residential Code.^1,2 Whether a reroof needs a permit is decided locally. Two large cities show how far the rules differ.

San José. A permit is required when 25 percent or more of the roof is reroofed in any 12-month period. Less than 25 percent counts as a repair. Most permits are issued online through SJPermits.org. Properties in a Wildland Urban Interface area cannot use the same-day counter services.¹

San Diego. Information Bulletin 123 (September 2026) says no permit is needed to renew roof coverings when the roof structure, including the roof diaphragm, is not altered. A permit is required when framing or decking must be replaced. It is also required when shakes or shingles give way to roofing heavier than 6 pounds per square foot, when skip sheathing is removed, or when the site is historic.²

Cool Roof Rules in the 2025 Energy Code

Buildings whose permit applications are filed on or after January 1, 2026, must comply with the 2025 Energy Code (Title 24, Part 6).³ Reroofing is an alteration under that code, not a repair. That includes replacing wood shakes with asphalt shingles.⁴

For homes, the Energy Commission's compliance manual says cool roof rules start when 50 percent or more of the roof area is replaced. Its summary table words the trigger as more than 50 percent.⁴

A steep-slope home is exempt from the cool roof product rule if it has any one of these:⁴

• ceiling insulation of R-38 or more;
• an attic radiant barrier meeting Section 150.1(c)2;
• no ducts in the attic, in climate zones 2, 4, 9, 10, 12 and 14;
• insulation of R-2 or more above or below the roof deck.

Nonresidential buildings follow Section 141.0(b)2B instead.⁴ San Diego's bulletin also points reroofers to Section 150.2(b)1I.²

Fire Hazard Zones and Class A Roofs

Health and Safety Code 13132.7 sets the minimum fire rating of a roof covering. Each tier covers new roofs and existing roofs where more than 50 percent is replaced within one year.⁵

• All areas: at least Class C.
• State Responsibility Areas, except moderate zones: at least Class B.
• Very High Fire Hazard Severity Zones, mapped by the state or a local agency: at least Class A.

In Very High zones, the Class A rule also covers any roof covering applied in a repair or replacement. A city that adopts the State Fire Marshal's model ordinance is exempt from that paragraph. Cities and counties may set stricter rules.⁵

San Diego is one that does. It requires a Class A assembly for all roof replacements, alterations and repairs. If more than 25 percent of the roof is redone in 12 months, the entire roof must be Class A.² San José states the state minimum, Class C.¹

Chapter 7A has moved. In the 2025 code, the wildfire construction rules left Chapter 7A of the Building Code. They now sit in the California Wildland-Urban Interface Code, Part 7 of Title 24.⁶ The 2025 Title 24 took effect January 1, 2026.¹⁶ The State Fire Marshal says this code applies to new buildings in State Responsibility Areas in moderate, high and very high zones. It also covers very high and high zones mapped by local agencies.⁷ San Diego applies its Chapter 5 to reroofs in Very High zones, for buildings built on or after August 27, 2009.²

To see your zone, use the Fire Hazard Severity Zone viewer on the State Fire Marshal's site.⁸

The C-39 License and the Workers' Comp Rule

C-39 Roofing is the CSLB class for contractors who install products and repair surfaces that seal, waterproof and weatherproof structures.⁹ A B General Building contractor cannot take a prime contract for roofing alone. It needs the specialty license or a licensed specialty subcontractor.¹⁵ See California license classifications.

Most licensees can file an exemption from workers' comp if they have no employees. Business and Professions Code 7125(b) denies that exemption to five classes, including C-39.¹⁰ CSLB states that every active C-39 contractor must carry workers' comp or self-insurance, "whether or not they have employees."¹¹

A later version of 7125 becomes operative January 1, 2028. From then on, nearly every active license must keep a workers' comp certificate on file.¹⁰ More on this: workers' comp on a license.

After Storms and Wildfires: What CSLB Warns

CSLB states that contracting without a license in a declared disaster area is a felony.¹² The penalty under Business and Professions Code 7028.16 reaches $10,000, prison of 16 months to three years, or both.¹⁴

CSLB's advice to disaster survivors:¹²

1. Hire only licensed contractors, ask to see the license and verify it on cslb.ca.gov.
2. Do not rush, and do not hire the first contractor who comes along.
3. Pay no more than 10 percent down or $1,000, whichever is less.
4. Do not pay cash, and do not let payments get ahead of the work.
5. Get three bids, check references and get a written contract.

CSLB also notes that all reconstruction in a declared disaster area counts as home improvement. Progress payments may not exceed the work done or materials delivered.¹³ See home improvement contracts.

After the January 2025 Palisades and Eaton fires, CSLB reported this field work for 2025:¹³