Minnesota has the 2024 building codes open for comment with no closing date
Minnesota has the 2024 building codes open for comment with no closing date
2026-09-12 · Minnesota · Regulation · Proposed — not yet introduced
What happened. The Minnesota Department of Labor and Industry has the 2024 editions of the I-Codes open for public comment across the Minnesota State Building Code, at the pre-draft stage. No rule text has been written, no hearing scheduled, and no effective date set for any of them.
The comment window has no closing date, which is the actionable point here rather than a deadline.
The dockets, and where they were published
State Register, Volume 49, Number 30 (21 January 2025), pages 857–888, opened Requests for Comments on:1
- Minn. R. ch. 1300–1303 — code administration
- ch. 1305 — the 2024 International Building Code
- ch. 1307 — elevators
- ch. 1311 — the 2024 International Existing Building Code
- ch. 1341 — the Accessibility Code (chapter 11 of the 2024 IBC plus section 306 of the 2024 IEBC)
State Register, Volume 50, Number 31 (2 February 2026), pages 777–804, added:2
- ch. 1322 — the Residential Energy Code, considering incorporation of chapter 11 of the 2024 International Residential Code
- ch. 1346 — mechanical and fuel gas
Statutory authority cited: Minn. Stat. §§ 326B.02, subd. 5; 326B.101; and 326B.106, subd. 1.
The comment terms, in the notices' own words
“Interested persons or groups may submit comments or information on these possible rules in writing until further notice is published in the State Register that the Department intends to adopt or to withdraw the rules. The Department will not publish a notice of intent to adopt the rules until more than 60 days have elapsed from the date of this request for comments.”
Comments go to Amanda Spuckler at DLI, 443 Lafayette Road N., St. Paul, MN 55155, or [email protected].3
The ch. 1322 notice names those affected to include “building owners and managers” alongside building officials, contractors, architects and homeowners.
Why chapters 1311 and 1341 are the ones to read
Most Minnesota association capital work is not new construction. It is rehabilitation of existing buildings: re-roofs, siding and envelope replacement, window replacement, balcony and deck repair, mechanical replacement, elevator modernisation, and accessibility upgrades in common areas.
Two dockets govern exactly that. Chapter 1311 adopts the International Existing Building Code, which sets what a repair, alteration or change of occupancy in an existing building must bring up to current standard. Chapter 1341 is the Accessibility Code, which reaches common areas and the circumstances under which alteration work triggers accessibility compliance.
The practical exposure for a Minnesota association is a code cycle that widens what counts as an alteration requiring compliance, or narrows a repair exemption. That is a line item on a reserve schedule, and it is being written now, in a docket with no draft text and an open comment window.
What Minnesota does not have, and is not proposing
Two absences worth stating plainly, because they are frequently assumed the other way.
There is no Minnesota milestone-inspection mandate. No trigger age, no fixed inspection interval, no inspector-credential requirement, no phased-inspection structure. Nothing in any of these dockets proposes one. The duty to maintain under Minn. Stat. § 515B.3-107 is a general standard, not a scheduled inspection.
There is no balcony or exterior-elevated-element inspection requirement. Minnesota has no analogue to California's Civil Code § 5551 regime, and nothing in the ch. 1311 docket proposes one.
So the real inspection triggers for a Minnesota association remain what they have been: the building code at construction and alteration, the separate periodic requirements for fire and elevator systems, insurer underwriting conditions, and whatever the declaration itself requires. Of those, the carrier is currently the most demanding.
The FORTIFIED recommendation runs through this process
Minnesota's Task Force on Homeowners and Commercial Property Insurance recommended, in its 13 February 2026 final report, that DLI “incorporate elements of the IBHS FORTIFIED roofing standards into residential and commercial building codes for new construction, through the Construction Codes Advisory Council process.”4
That is a recommendation about these dockets. It is not law, no draft rule contains it, and the task force expired on submitting the report — so nobody is carrying it forward institutionally.
For an association, the connection is concrete: Commerce has separately published benchmark wind-and-hail premium credits of 35, 38 and 40 percent for FORTIFIED Roof, Silver and Gold construction. A code that required FORTIFIED elements on new work would move that from an optional specification to a baseline.
The one docket that did complete
Worth naming so the picture is not misleadingly static. Minn. R. ch. 3801 (electrical procedures) ran the full cycle: request for comments 18 August 2025, dual notice 22 December 2025, comment period closed 21 January 2026 without the 25 hearing requests that would have forced a hearing, ALJ approval 19 February 2026, filed with the Secretary of State 27 February 2026, effective 30 March 2026.5
Its content is electrical-equipment-approval terminology and permit requirements, and it reaches an association no differently from any other property owner. It is included here to show the process does conclude — and roughly how long it takes from request for comments to effective date. On that timeline, the 2024 I-Code dockets opened in January 2025 are running slowly.
What this means for a board or manager
The honest answer is that there is no compliance obligation here and no deadline. What there is, is an open door that will close without warning — the notices say comments are accepted “until further notice is published in the State Register.”
Associations with significant capital work planned in the next three to five years, and the managers and engineers who advise them, are among the few parties with concrete operational knowledge of how the existing-buildings and accessibility chapters land on a 1970s or 1980s Minnesota condominium. That is the comment worth filing, and it costs an email.
Boards that do not intend to comment should still know that a code change is in the pipeline, because reserve studies written against the current code will be written against a superseded one at some point in the next few years.
What to watch next
The signal to watch for is a notice of intent to adopt published in the State Register for any of these chapters. That is when draft rule text appears and the process moves from open-ended comment to a formal timetable.
Every one of the eleven dockets currently shows rule draft, hearing, ALJ report, filing with the Secretary of State, and effective date all still to be determined.3
This describes an open rulemaking process. Nothing in it binds any Minnesota association today.
Related Minnesota HOA Topics
- Minnesota State Register, Vol. 49, No. 30 (21 Jan. 2025) — Requests for Comments on Minn. R. chs. 1300–1303, 1305, 1307, 1311, 1341 ↩
- Minnesota State Register, Vol. 50, No. 31 (2 Feb. 2026) — Requests for Comments on Minn. R. chs. 1322 and 1346 ↩
- Construction Codes and Licensing rulemaking index — Minnesota Department of Labor and Industry ↩
- Task Force on Homeowners and Commercial Property Insurance, Final Report to the Minnesota Legislature (13 Feb. 2026) ↩
- Rulemaking docket, Minn. R. ch. 3801 — Minnesota Department of Labor and Industry ↩
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