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Guide · Code reference

Maryland Building Performance Standards plan review: the 2021 IBC, IRC, and IECC, the withdrawn 2024 update, and local amendments

Maryland sets one statewide building code, the Maryland Building Performance Standards, and leaves its enforcement and most amendments to the counties and municipalities. The state version replaces the IBC’s accessibility chapter with its own code and sends electrical, mechanical, and plumbing work to other adopting bodies. Groundbook can compare the drawings with the COMAR chapters, model codes, and local amendments you upload and flag where the code analysis cites an edition or chapter Maryland did not adopt.

For a building in Maryland, check that the code analysis cites the Maryland Building Performance Standards, COMAR 09.12.51, which incorporates the 2021 IBC, IRC, and IECC with state modifications, effective May 29, 2023, together with the local jurisdiction’s amendments and the Maryland Accessibility Code in place of IBC Chapter 11. A proposal to adopt the 2024 editions was withdrawn in October 2026, so the 2021 editions remain current. AI can flag conflicts; the design professional and the local building official decide compliance.

What do the Maryland Building Performance Standards cover?

The Maryland Department of Labor’s Building Codes Administration describes the Maryland Building Performance Standards (MBPS) as the state law requiring every jurisdiction to use the same edition of the IBC, IRC, and IECC, as the state modifies them. COMAR 09.12.51.04 incorporates the 2021 IBC, the 2021 IRC, and the 2021 IECC and lists the Maryland modifications. Those include notes that the IBC electrical, mechanical, and plumbing chapters are outside the MBPS and governed by the codes other bodies adopt, the replacement of IBC Chapter 11 with the Maryland Accessibility Code in COMAR 09.12.53, the routing of work on existing buildings to the Maryland Building Rehabilitation Code in COMAR 09.12.58, the adoption of IBC Appendices C, G, and H, and changes to individual IBC sections, among them the occupant load at which Group A fire alarm initiation applies. The energy modifications add a hotel guest room master control requirement and Maryland residential alternatives. Regulation .08 makes enforcement the responsibility of the local jurisdiction, and the Department’s code page notes that state-owned and industrialized (modular) buildings follow the separate Model Performance Code, COMAR 09.12.50.

The Department’s code administration notice says the 2021 IBC, IRC, and IECC took effect May 29, 2023, with local jurisdictions required to implement and enforce them by May 29, 2024, and its effective dates page lists the earlier cycles back to 2001. Regulation .06 applies the Standards to buildings for which a local jurisdiction receives a building permit application and gives jurisdictions 12 months after a state amendment to enforce it. The state codes page explains that state law has the Department adopt each new model code within 18 months of its issuance. On its What’s New page, the Department says a proposal to adopt the 2024 IBC, IRC, and IECC was published in the Maryland Register on June 26, 2026, and was then withdrawn in its entirety, with a notice of withdrawal published October 16, 2026, while the Department works through comments on the energy provisions. The code matrix dated March 18, 2026 lists the 2021 IBC, IRC, and IECC, the 2021 IEBC as the Rehabilitation Code, and the 2019 Maryland Accessibility Code. All checked October 29, 2026. Do not cite a 2024 I-Code as Maryland’s code until the Department adopts it, and confirm the edition the local jurisdiction enforces on the permit application date.

Under Regulation .05, each jurisdiction may amend the Standards for local conditions, and a local amendment prevails where it conflicts, but a jurisdiction may not weaken the IECC or IBC Chapter 13, the sprinkler provisions for townhouses and one- and two-family dwellings (with a statutory exception), or the wind design provisions. The Maryland Accessibility Code scope covers new construction, additions, alterations, and changes of use, except listed buildings such as residential buildings of fewer than four units, and regulation 09.12.53.07 applies the 2010 ADA Standards to private buildings with additional Maryland requirements. COMAR 09.12.58.03 adopts the 2021 IEBC as the Rehabilitation Code; the Department’s rehabilitation web page still names the 2015 IEBC, so confirm the edition with the jurisdiction. The trade codes page says the State Fire Marshal adopts the electrical code, the Board of Plumbing oversees plumbing, and the Department adopts the mechanical code, with local adoptions in some jurisdictions. Fire protection is also covered by the State Fire Prevention Code, COMAR 29.06.01, enforced by the State Fire Marshal or the local fire official. Local routing is on the Maryland page, and the model codes have their own guides: IBC, IRC, IECC, IEBC, and ADA Standards.

Gather the code analysis, the local amendments, and each discipline’s adopting body

Collect the cover sheet and code analysis with the MBPS, IBC, IRC, IECC, and local amendment citations, the architectural plans, sections, life safety plans, and door schedules, the accessibility plans and details, the structural general notes with the wind and flood basis, the fire alarm and sprinkler drawings, the mechanical, plumbing, and electrical drawings, the energy compliance documentation, and the specifications.

Add the jurisdiction and its current building code ordinance, the planned permit application date, whether the building is privately owned, state-owned, or modular, the fire code that applies (the State Fire Prevention Code or a local fire code), and, for existing buildings, the scope of work and the Rehabilitation Code work category.

Trace the MBPS and its companion codes through the set

Maryland Building Performance Standards document coordination checksSwipe or scroll sideways to read all columns.
Review questionSources to compareDecision to record
Code edition and jurisdictionCover sheet, code analysis, general notes, local ordinanceConfirm the MBPS on the 2021 IBC, IRC, and IECC is cited with the local amendments, not the 2024 I-Codes from the withdrawn proposal or an unamended model code.
Accessibility basisAccessibility plans and details, code analysis, unit countCheck that accessible elements cite the Maryland Accessibility Code and the 2010 ADA Standards it applies, rather than IBC Chapter 11 alone, unless the jurisdiction has adopted Chapter 11 as well.
Existing building workScope of work, demolition and alteration plans, code analysisConfirm that repairs, alterations, additions, and changes of occupancy cite the Maryland Building Rehabilitation Code and the IEBC edition the jurisdiction enforces.
Fire protection and fire codeFire alarm and sprinkler drawings, occupancy data, specificationsCheck that alarm and sprinkler notes reflect the Maryland IBC modifications and that the applicable State Fire Prevention Code or local fire code is identified.
Energy path and local stringencyEnergy forms, envelope details, lighting controls, hotel room controlsMatch the energy documents to the 2021 IECC as modified, including hotel guest room controls, and any local provisions that are more stringent.
Trade code adoptionsMechanical, plumbing, and electrical notes and specificationsRecord the mechanical, plumbing, and electrical code editions the jurisdiction and state boards enforce, since these chapters sit outside the MBPS.

Accessible details continue in the ADA Standards guide, the Fair Housing Act guide, and the accessibility checklist, fire protection in the NFPA 101 guide and the NFPA 13 guide, mechanical sheets in the mechanical drawing checklist, electrical sheets in the electrical drawing checklist, and the full set in the architectural drawing checklist. Neighboring state codes are in the Virginia USBC guide and the Pennsylvania UCC guide.

Example: a hotel drawn to the proposed 2024 codes

Hypothetical example. A five-story hotel in Anne Arundel County is drawn in summer 2026 by a team that expected Maryland’s 2024 update to take effect. The code analysis cites the 2024 IBC and IECC, the accessibility sheets cite IBC Chapter 11 and ICC A117.1 without the Maryland Accessibility Code, the energy notes do not address guest room master controls, and a ground-floor renovation of an existing building on the site is cited to the IBC instead of the Rehabilitation Code.

The code analysis cites the 2024 IBC and IECC, while COMAR 09.12.51 incorporates the 2021 editions and the Department withdrew the 2024 proposal in October 2026. The accessibility sheets cite IBC Chapter 11, which the MBPS replaces with the Maryland Accessibility Code, the energy notes omit the hotel guest room control modification, and the renovation is not cited to the Maryland Building Rehabilitation Code. Confirm the code basis and local amendments with the county and coordinate the code analysis, accessibility, energy, and renovation sheets.

The architect confirms the code basis with the county building official, revises the accessibility references to the Maryland Accessibility Code, adds the guest room controls to the energy and electrical sheets, and cites the Rehabilitation Code for the renovation. The finding is a citation conflict; the local building official decides compliance.

Review a Maryland set with Groundbook

Upload the current drawings and specifications to Groundbook, and state the edition, amendments, and review scope in your instructions. COMAR 09.12.51, 09.12.53, and 09.12.58 are free on the Library of Maryland Regulations site, and the Department links the official copies from its code pages. Upload the COMAR chapters and the local building code ordinance as code files, with the 2021 IBC, IRC, IECC, IEBC, and the standards they reference, using copies you are licensed to use where the license permits uploading them. See how Groundbook works with local and licensed codes.

Compare the cover sheet, code analysis, and every discipline’s general notes with the architectural, life safety, accessibility, structural, fire protection, mechanical, plumbing, electrical, and energy documents. Flag citations to the 2024 I-Codes or unamended model codes instead of the MBPS on the 2021 IBC, IRC, and IECC with local amendments, accessibility cited to IBC Chapter 11 without the Maryland Accessibility Code, existing building work not cited to the Maryland Building Rehabilitation Code, notes that rely on IBC or IECC sections COMAR 09.12.51.04 modifies, and mechanical, plumbing, or electrical notes with no adopting code identified. Use the supplied COMAR chapters, local amendments, and model codes and cite both sources.

Groundbook links each potential finding to the note or sheet and to the COMAR regulation, local amendment, or model code you uploaded. It compares what the documents state; it does not decide which edition or local amendment governs.

Document review does not certify compliance, issue a permit, or replace the design professional, the local building official, the fire official, or the Building Codes Administration.

Questions, answered

FAQs

Which building code is in effect in Maryland in 2026?

COMAR 09.12.51 incorporates the 2021 IBC, IRC, and IECC with Maryland modifications, effective May 29, 2023. A proposal to adopt the 2024 editions was published June 26, 2026 and withdrawn, with a notice published October 16, 2026.

Does Maryland use IBC Chapter 11 for accessibility?

No. The MBPS replaces IBC Chapter 11 with the Maryland Accessibility Code, COMAR 09.12.53, which applies the 2010 ADA Standards with added Maryland requirements. A local jurisdiction may also enforce Chapter 11 where it meets or exceeds the state code.

Can Maryland counties amend the building code?

Yes. Under COMAR 09.12.51.05, a local jurisdiction may amend the Standards for local conditions, but it may not weaken the IECC, IBC Chapter 13, the residential sprinkler provisions except as the statute allows, or the wind design provisions.

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