Chicago facade reports are due November 1 and December 1, and your amenity deck counts
Chicago facade reports are due November 1 and December 1, and your amenity deck counts
2026-09-10 · Illinois · Compliance
What is happening. Chicago's facade ordinance — Municipal Code §§ 13-196-031 and 13-196-035 — and the City of Chicago Rules Regarding the Maintenance of High-Rise Exterior Walls and Enclosures impose recurring deadlines that fall in the next twelve weeks.1
- Ongoing Inspection reports are due November 1.
- Critical Examination reports are due December 1.
No 2025 or 2026 amendment to the ordinance or the Rules was found; the current Rules took effect March 1, 2016. The Department of Buildings posts separate 2025 and 2026 Exterior Wall Forms. The deadlines are the live item.
Who it binds
Exterior walls and enclosures of all buildings 80 feet or more in height — roughly seven to eight stories — including balconies, fire escapes and signs. That is most downtown, Gold Coast, Lakeview and Hyde Park condominium high-rises.
The inspection must be by, or under the direct supervision of, an Illinois-licensed architect or structural engineer retained by the owner, who files a signed and sealed report classifying the facade as:
- Unsafe and Imminently Hazardous;
- Safe with a Repair and Maintenance Program; or
- Safe
— plus the filing fee and two paper copies.
The two compliance paths
Critical Examination and Ongoing Inspection Program. Frequency turns on cladding category:
- Category I (non-corrodible metal): critical exam every 12th year, ongoing inspection every 6th.
- Category II (corrosion-resistant or protected corrodible metal): critical every 8th year, ongoing every 4th.
- Category III (corrodible metal): critical every 4th year, ongoing every 2nd.
- Category IV (adhesive bond or masonry headers): critical every 8th year, ongoing every 4th.
Ongoing Inspection and Repair “Short Form Only” Program. A visual, non-close-up inspection every two years, with no further critical exams unless the facade is found unsafe and imminently hazardous. A building qualifies after completing a critical exam — unless it is vacant and subject to registration, is subject to an active case, outstanding order of compliance or consent decree before the Department of Administrative Hearings or the Circuit Court of Cook County, was classified unsafe and imminently hazardous in its most recent report, or the owner is more than one year delinquent in filing a Short Form report. New buildings may enter Short Form directly by completing an ongoing inspection within two years of initial occupancy.
Two things boards routinely get wrong
1. The amenity deck needs a scaffold drop. A critical exam requires a close-up hands-on inspection from suspended scaffold of at least one representative section spanning at least 24 feet in width on each elevation above a public way — and “public way” is not just streets, alleys, sidewalks, rights of way and parks. It includes private areas regularly used by occupants: rooftop terraces, amenity decks, and uncovered parking areas.
Boards budget for the street elevations and are surprised by the courtyard and the roof deck.
2. One “unsafe” classification ejects you from the cheap path. A building on the biennial Short Form programme that receives an unsafe and imminently hazardous classification goes back to full critical examinations — a swing of tens of thousands of dollars per cycle, indefinitely.
For buildings 50 years or older with masonry, stone or terra cotta cladding affixed by concealed corrodible or corrosion-resistant metal fasteners, the professional must create inspection openings. Where unsafe and imminently hazardous conditions are found, the professional must notify the Commissioner of Buildings immediately and develop a repair plan and schedule.
On penalties: a compliance guide reports $500 to $1,000 per day for failure to file and $1,000 per day where unsafe conditions persist. That guide also miscites the requirements to Chapter 14-12 rather than 13-196, so treat the penalty figures as unverified.
The Illinois context that makes this matter more
This is the only structural-inspection mandate in Illinois. The state has enacted nothing comparable to Florida's or New Jersey's milestone-inspection regimes, no standalone inspection bill surfaced in the 104th General Assembly, and the task force chartered to study “safe living conditions” died in Rules.
Outside Chicago, an aging Illinois high-rise is inspected when its board decides to inspect it — and with no reserve-study requirement either, often it does not.
What to watch next
CAI's national policy now supports laws providing for ongoing inspections of building structures and facades, a plank added in February 2024. That is the piece Illinois has not yet seen in bill form.
Related Illinois HOA Topics
- Simpson Gumpertz & Heger, topic brief on the Chicago facade ordinance (categories, cycles, scaffold requirements) ↩
- Chicago facade ordinance compliance reference (filing deadlines and report classifications) ↩
- Chicago building compliance guide (facade, life safety and benchmarking obligations) ↩
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