What are Building Codes?

Building Codes are developed by the Federal government via the Canadian Commission on Building and Fire Codes and published by the National Research Council of Canada.

Provinces then adopt, sometimes they make some amendments.   Manitoba must adopt the updated codes within 18 months of publication under Canadian Free Trade Agreement commitments and is working to advance a regulatory adoption accordingly.

Municipalities implement codes through permits and inspections.

UPCOMING CODES – 2025 Building Codes Update

The National Research Council published the 2025 editions of the national model construction codes (building, plumbing energy and fire) on December 22, 2025. and now the Manitoba Government has 18 months to implement.

On September 23rd Manitoba opened public consultation on proposed updates to the Building, Plumbing, Energy and Fire Codes. The updates adopt the 2025 National Model Codes and include the province’s first mandatory increase in energy efficiency tiers under the National Building Code (NBC) and National Energy Code for Buildings (NECB) . These are draft regulations and may change after consultation. Here’s what code users need to know, and why we think the province needs to move faster.

What’s changing and when

On June 22, 2027, Manitoba will adopt the 2025 editions of the national codes. This is a proposed regulatory adoption project and is not finalized until Cabinet actually approves a regulation.

On January 1, 2028, the province proposes raising the energy requirements:

• Houses and small buildings under Part 9 of the NBC move from the current baseline of Tier 1 to Tier 3. That means using at least 20% less energy than a code-minimum reference house.
• Larger buildings under Part 3 of the NBC must comply with the NECB and move from Tier 1 to Tier 2, a 25% improvement.

The national codes also bring close to 400 technical changes of their own, including new requirements for accessibility, radon mitigation, window performance and structural loads. The province, citing National Research Council analysis, estimates these national changes add $2,955 to $5,078 to the cost of a house. That estimate doesn’t include the energy tier increase, covered below.  The Canadian Board for Harmonized Construction Codes has a summary of the key changes.

Some of the changes

Energy performance is measured in tiers, with each tier requiring a larger improvement over the baseline. Here’s where Manitoba’s codes sit today, and where they’re going in 2028.

The code makes a delineation under the NBC for smaller homes based on conditioned space as follows:

A 300 m³ would be a very small home in terms of floor space, well below the average newly built Manitoba home.

Manitoba also adds its own amendments to the national codes. Some of the changes are new, but most carry forward from the current code, so much of the provincial rulebook will look familiar.

Table covers selected Building Code and Energy Code amendments only.

Watch your permit dates

Which rules apply depends on when a project is permitted, not when it breaks ground.

A project in design today could easily land in that last row. If it will be permitted in 2028, design it for Tier 3 now.

What it costs, and what it saves

The province’s market assessment estimates that building a home to Tier 3 instead of Tier 1 adds about $4,850, paid back through utility savings in about 8.4 years. The province doesn’t say how much this overlaps with the national code changes above. It’s also a worst case for a home built to today’s minimum. Many Manitoba homes are already built above the minimum, and the province notes costs will likely be lower. For buyers, the energy upgrade pays from day one. Rolled into a 25-year mortgage, it adds roughly $27 a month, while the bill savings average about $48 a month.

The cheapest time to build in energy efficiency is when a building goes up. Adding it later through retrofits typically costs more, and it’s the homeowner who pays.

Why we need more urgency

It’s good that the requirements are finally going up. But both of these increases are where Manitoba should have started when the current codes took effect in 2024, instead of adopting Tier 1 across the board. For houses, Tier 3 largely formalizes what much of the industry already builds. The province also says the next tier increase will wait for the next code cycle, likely not before the early 2030s.

That’s too slow. Manitoba Hydro’s 2025 Integrated Resource Plan says the province needs about 1,760 MW of new winter capacity by 2035, and it counts on customer-side measures like energy efficiency for nearly half of it. Buildings drive a large share of winter peak demand. Most homes and buildings we put up this decade will still be standing, and drawing on that grid, in 2100. Whatever we don’t build in now becomes a retrofit bill for the owner later, or new generation paid for by every ratepayer.

We’re also leaving a lot on the table. By the province’s own figures, the top tiers cut energy use by at least 60% compared with Tier 1, three times what Tier 3 requires for houses.

The province’s Path to Net Zero commits to working with the building sector to adopt the highest tier for all building types over time. But its Three-Year Action Plan sets no schedule for the next step, and funds industry training only for 2026/27.

Builders can handle higher standards. What we can’t plan around is uncertainty. We’re calling on the province to publish a firm timeline to the top tiers for both the NBC and the NECB, starting well before the next code cycle. We’re also asking it to fund training through the transition, not just the year before it.

Have your say

Consultation closes October 23, 2026, at noon. The draft regulations and feedback form are on EngageMB. A few sentences is enough. You might share:

• Your view on the move to NBC Tier 3 and NECB Tier 2 in 2028, and what your business needs to be ready for it.
• That builders need a published timeline to the top tiers, set well before the next code cycle.
• That training funding should continue through the transition, not end in 2027.

Getting ready for new energy tiers? Sign up in the next section.

The codes are available on the NRC’s publications website and can be viewed freely.

A summary of key changes included in the 2025 editions of the national model codes can be accessed on the Canadian Board for Harmonized Construction Codes website.

CURRENT BUILDING CODES – 2020

On January 1st 2024 the 2020 editions of the national model building, plumbing, energy and fire codes published by the National Research Council (NRC) will come into effect and be enforced.  For energy efficiency, it is Tier 1 across the board for both commercial and residential.

Permitting and inspections authorities responsible for adopting and enforcing the Manitoba Building Code, Manitoba Plumbing Code and Manitoba Energy Code for Buildings will be required to approve building and plumbing permits based on the 2020 national model codes starting January 1, 2024. Inspections based on permits approved before January 1, 2024 must ensure compliance with approved plans based on the previous codes.

Manitoba’s construction codes are adopted with Manitoba specific amendments by regulation and are available on the Manitoba Laws website:

The Manitoba Building Code regulation:
M.R. 78/2023, Manitoba Building Code (gov.mb.ca)
The Manitoba Plumbing Code regulation:
M.R. 80/2023, Manitoba Plumbing Code (gov.mb.ca)
The Manitoba Energy Code for Buildings regulation:
M.R. 79/2023, Manitoba Energy Code for Buildings (gov.mb.ca)
The Manitoba Fire Code regulation
M.R. 82/2023, Manitoba Fire Code (gov.mb.ca)

These codes are the first to have energy efficiency Tiers.

The 2020 editions of the codes allow provincial and territorial regulators to select energy efficiency tiers for housing and small buildings under the National Building Code, with five tiers to choose from, and large or complex buildings under the National Energy Code for Buildings, with four tiers to choose from. The highest tiers for either code means a building realizes at least a 60 per cent reduction in energy consumption over the baseline Tier 1 and is a step towards Canada developing net-zero emissions codes by 2050, when new buildings will be powered entirely from non-emitting sources.

Manitoba is initially adopting the baseline Tier 1, for the building and energy codes and is working with the federal government to develop a roadmap and to build capacity in Manitoba for higher tier adoption in the future. Tier 1 represents approximately a 20 per cent energy efficiency improvement over the previous Manitoba requirements for large and complex buildings. While Tier 1 for housing and small buildings under the 2020 National Building Code remains comparable to the previously adopted 2010 edition, Manitoba will continue to have additional requirements for heat-recovery ventilation in residential applications on top of the national requirements, while working towards adopting higher tiers.

Learn more about Tiered Building Codes – What They Are, Why They Matter, and What It Means for Existing Buildings in Canada from Manitoba’s own ioAirFlow

Manitoba Government Powerpoint Template about energy efficiency code adoption.

TRAINING

Here are some resources on the new codes to help you familiarize yourself with them.

• Recordings of old sessions from Engineers and Geoscientists on the Climate West site
• An Introduction to Climate Change Through Codes, Standards and Regulations and Presentation Slides
• NECB 2020 Free online training developed by NRC and  CSA Group:
  • NECB 2020 Training – Navigating and Applying the Code
  • NECB 2020 Training – Contractor
    
  • NECB 2020 Training – Designer

RESOURCES

Inspection and Technical Services, Manitoba provides a comprehensive collection of documents designed to support compliance with provincial safety standards and regulations. The materials are categorized into three main types:​

Bulletins: These are official communications that offer updates, clarifications, and interpretations of codes, regulations, and procedures related to various technical safety areas. For example:​

1. • ITS 25-003 – Engineered Roof Trusses and Floor Joists: Provides guidance on the use and inspection of engineered roof components.

   • ITS 22-017 – Tiny Homes: Offers information on regulatory considerations for tiny homes.​

Guides: These documents serve as instructional resources to assist stakeholders in understanding and applying specific codes and standards. Examples include:​

• ITS BC Guide 04 – Part 9, New Dwellings and Additions: Offers guidance on constructing new dwellings and additions under Part 9 of the building code.​

• ITS BC Guide 05 – Building Permit Guide: Highlights information required when applying for a building permit.

Forms: A variety of standardized forms necessary for applications, permits, inspections, and certifications. Examples:​

• • ITS BC Form 25 – Building Permit Application: Used to apply for a building permit.​

  • ITS CS Form 04 – Application for Power Engineer Licence: Required to obtain your licence to practice as a power engineer in Manitoba.

These resources are intended to facilitate compliance with Manitoba’s safety regulations across various sectors, including building construction, boiler and pressure vessels, elevating devices, gas and oil installations, and trade certifications. They are regularly updated to reflect current standards and practices.​

Significant Technical Changes – 2020 National Model Codes

Nearly 400 technical changes approved by the Canadian Commission on Building and Fire Codes are introduced in the 2020 editions of Canada’s National Model Codes. The most significant technical changes NATIONAL ENERGY CODE OF CANADA FOR BUILDINGS (NECB) are summarized below.

Click here to see a summary of all the different codes areas that was put together by the Canadian Commission on Building and Fire Codes.

Application
The application of the NECB is extended to cover alterations, such as tenant improvements, to buildings originally constructed in accordance with the Code.

Building envelope
Whole-building airtightness testing is introduced as an option for complying with air leakage requirements. Maximum overall thermal transmittance values for opaque building assemblies and fenestration are reduced to improve the thermal performance of the building envelope.

Lighting
Lighting power densities are updated to reflect improvements in the efficacy of lighting products available in the North American market. Lighting power allowances are provided for use in additional exterior applications, including applications not listed in the Code.

HVAC and service water systems
The trade-off compliance paths for HVAC and service water systems, which were complex and not widely used, are removed. Performance requirements for HVAC and service water heating equipment are updated to align them with Canada’s Energy Efficiency Regulations and relevant standards, and to add new equipment types.

Tiered energy performance compliance
New Part 10 is introduced to establish a performance compliance path with 4 tiers, each successive tier being increasingly stringent in terms of building energy consumption.

Proposed National Building Code Energy Efficiency Requirements

Future Codes

In 2021 the Manitoba Government passed Bill 38 (The Building and Electrical Permitting Improvement Act) to harmonize with the National model building codes.

SBM submitted this letter of support for Bill 38 in January 2021

Some additional background:

1. The 24 month and 18 month period in the legislation is required to allow projects in the design phase to proceed to construction/permitting phase with certainty of not having to redo the design.  Developers, consultants and contractors require this certainty for budgets, schedules, etc.  It also allows time for the stakeholders to be educated on the additional requirements in the new code.  In other words, you can’t just flip a switch and have the code come into effect without a lot of market disruption.  Please note that NECB 2011 was proclaimed on December 20, 2013 and came into effect in Manitoba on December 31, 2014 and that SBM and others did lots of educational programming for that to happen so quickly!

2. Here is the Regulation that adopted the NECB 2011 and amendments.  It is hard to tell  how significant the amendments were but there is nothing in Bill 38 that prohibits Manitoba from doing amendments.  The opinions are that the new code requirements and frequency of new codes are going to be so incrementally greater than previous, that amendments will not be an issue anyways – it will be fast and furious!

3. It has been mentioned that the Manitoba Building Codes committee is not active any longer and that Manitoba input into the code development will be diminished. The Canadian Commission on Building and Fire Codes policy position is to “analyze the impact of a uniform performance goal for all of Canada compared to regionally-specific goals and pay particular attention to constraints in Canada’s North.”  As well, CCBFC works closely with the Provincial/Territorial Policy Advisory Committee on Codes (PTPACC) of which Manitoba is represented.