Barrier-free access requirements for commercial renovations and change of use

If you are renovating a commercial bay or changing the type of business operating in a space, barrier-free accessibility requirements may apply.

Barrier-free means a space is designed so people of all abilities can enter, move through and use it independently and safely. It removes physical obstacles that make access difficult for people with mobility, vision, hearing or other physical challenges.

Under the National Building Code – 2023 Alberta Edition (NBC(AE)), updated requirements for power door operators and accessible washrooms came into force on May 1, 2024. These requirements now apply in more situations than under previous codes.

This page explains when the rules apply and what to expect.

See National Building Code - Alberta edition

Barrier-free accessibility requirements apply to:

• New construction
• Additions
• Renovations or alterations to a building or tenant bay
• Change of use or occupancy

If you are changing how a space is used, current code requirements must be applied, even if you are not planning major renovations.

Under Article 3.8.2.7 of the NBC(AE) 2023, power door operators are required on doors that are:

• At a pedestrian entrance to a building
• On interior vestibule doors at an entrance
• In public corridors between the entrance and individual suites along a barrier-free path of travel
• At the entrance to a washroom that contains a barrier-free water closet
• In barrier-free hallways within physician clinics and offices

These requirements apply to new construction and when renovations or a change of use is taking place.

Under previous codes, existing conditions could sometimes remain if specific areas were not being renovated.

Under the 2023 NBC(AE), if renovations are taking place within a building or tenant bay, barrier-free accessibility requirements must be considered more broadly.
For example:

• If a washroom is being renovated and made barrier-free, the entrance serving that space may also need to meet current accessibility requirements.
• If work is being done within a bay, accessibility cannot be ignored simply because the entrance or washroom is not part of the renovation scope.

The intent of the Code is to ensure accessibility throughout the renovated space.

If a space is changing from one type of use to another (for example, retail to office, or office to medical), the current Code requirements apply.

This means barrier-free accessibility requirements must be reviewed and implemented as part of the change of use, even if no physical renovations are planned.

This interpretation has been confirmed by Alberta Municipal Affairs.

Alberta Municipal Affairs has issued guidance under STANDATA 23-BCI-016R1 – Barrier-Free Design Requirements: Relaxations (PDF)
Barrier-free relaxations may only be granted by the Alberta Municipal Affairs Barrier-Free Administrator.

Applicants must have a complete building permit application prepared and submitted with the city before requesting an exception or relaxation through Alberta Municipal Affairs. Requests made prior to a building permit submission will not be accepted by Alberta Municipal Affairs.

Relaxations may be considered where:

• Compliance is unnecessary due to the nature of the occupancy, or
• Extraordinary circumstances prevent full conformance.

Relaxations will not be granted to:

• Reduce construction costs
• Correct missed Code requirements
• Fix construction errors
• Avoid evaluating alternative design solutions

Applicants must follow the formal process through Alberta Municipal Affairs.

Every project is unique. This information is provided for general guidance only and may not apply to specific site conditions.

For exact wording and final determination of compliance, refer to the National Building Code – 2023 Alberta Edition.

If you are planning a renovation or change of use, contact Building Inspections early in your project to confirm requirements.