2026 Lighting Control Codes: ASHRAE 90.1 & Title 24 Guide

Why Lighting Controls Are No Longer Optional

Lighting controls have moved from a design recommendation to a legal requirement across nearly all commercial occupancies. With the adoption of ASHRAE 90.1-2026 and continued enforcement of California Title 24, automatic shutoff, occupancy sensing, and daylight-responsive controls are now mandated by code—not left to designer discretion.

Failure to install required controls can result in failed inspections, permit delays, denied certificates of occupancy, and costly post-install retrofits.

How Title 24 and ASHRAE 90.1-2026 Work Together

ASHRAE 90.1 serves as the national energy standard adopted or referenced by most U.S. states. Title 24 (California Energy Code) builds on ASHRAE with stricter, more granular requirements.

For practical purposes:

ASHRAE 90.1-2026 establishes the baseline nationwide
Title 24 generally exceeds ASHRAE requirements
Compliance is evaluated by space type, not fixture type

If a project meets Title 24, it will typically exceed ASHRAE 90.1-2026.

Areas Where Occupancy Sensors Are Mandatory

Occupancy or vacancy sensors are now required in most enclosed and intermittently used spaces.

Space Type	Sensor Requirement	Notes
Private offices	Occupancy or vacancy sensor	Auto-off required
Conference rooms	Occupancy sensor	All lighting controlled
Restrooms	Occupancy sensor	No manual bypass
Storage rooms	Occupancy sensor	Including closets
Break rooms	Occupancy sensor	Partial-on allowed

Manual wall switches alone do not satisfy these requirements.

Where Automatic Shutoff Is Legally Required

Both codes mandate automatic shutoff of lighting during unoccupied periods.

Area	Shutoff Requirement	Maximum Time Allowed
Interior spaces	Automatic shutoff	30 minutes after vacancy
Whole building	Scheduled shutoff	Based on business hours
Exterior lighting	Time-based or photocell	Sunrise/sunset or curfew

Timeclocks must be programmable and tamper-resistant.

Daylighting and Zone Control Requirements

ASHRAE 90.1-2026 expands daylight-responsive control requirements.

Automatic dimming in daylight zones
Separate control zones within daylit areas
Continuous dimming preferred over stepped control

Daylight Source	Control Required	Applies When
Windows	Daylight dimming	Within daylight zone
Skylights	Daylight dimming	Primary sidelit areas
Clerestories	Independent zone control	Large open spaces

Binary on/off photocells do not meet 2026 daylighting intent.

Controls Checklist for 2026 Compliance

This checklist reflects minimum requirements—not best practices.

Control Type	Required	Applies To
Occupancy sensors	Yes	Most enclosed spaces
Automatic shutoff	Yes	All interior lighting
Daylight dimming	Yes	Daylit zones
Exterior controls	Yes	All outdoor fixtures
Manual overrides	Limited	Time-restricted

Projects that treat controls as accessories rather than code requirements risk enforcement action.

Under Title 24 and ASHRAE 90.1-2026, lighting controls are no longer a design preference—they are a legal requirement tied to occupancy, daylight availability, and operating hours for virtually every commercial square foot.

Brandon Waldrop

As the lead technical specialist for our commercial lighting technical operations, Brandon Waldrop brings over 20 years of industry experience in product specification, outside sales, and industrial lighting applications.

His career began in physical lighting showrooms, where he focused on hands-on product performance and technical support. He later transitioned into commercial outside sales, working directly with architects, electrical contractors, and facility managers to translate complex lighting requirements into energy-efficient, code-compliant solutions.

Today, Brandon applies that industry experience to architect high-performance digital catalogs and technical content systems, helping commercial partners streamline the specification process and deploy lighting solutions with total technical confidence.