BC Building Code and CSA B651: Which Accessibility Requirements Apply?

Southpointe Academy building with landscaped pedestrian paths and a parking area

Building codes and CSA accessibility standards have different roles in a project. An owner asking for an accessibility review needs to know which requirements govern the work and whether the appointment includes a broader assessment. A clear review basis helps designers respond to findings and helps owners understand which decisions they need to make.

Start with the governing code and jurisdiction

For a BC project, establish whether the BC Building Code applies and identify the relevant edition, amendments and transition provisions. The Province’s BC Building Code 2024 page explains the code’s application and links to supporting information. In the City of Vancouver, use the Vancouver Building By-law and its applicable provisions.

Then define the work: a new building, an addition, a tenant improvement or a review of an occupied facility. Record the proposed uses and areas affected. These inputs matter because the question “Does this building meet accessibility requirements?” is too broad to support a reliable scope without identifying what is being assessed.

What is CSA/ASC B651:23?

CSA/ASC B651:23, Accessible design for the built environment, addresses access for people with physical, sensory and cognitive disabilities. Accessibility Standards Canada and CSA Group developed the standard. It provides a technical basis for considering physical spaces and their elements.

The published B651:23 standard includes requirements and explanatory material. A review needs to identify which clauses apply to the particular spaces and features. Simply adding “CSA compliant” to a design brief leaves the edition, coverage and evidence unclear.

Does the newest CSA edition automatically apply?

No. Publication of a newer standard does not, by itself, change the governing building code. Where a code references a standard, check the adopted edition and the scope of that reference. Confirm those details from the applicable code rather than assuming that every provision of the newest B651 edition is mandatory.

An owner may also specify CSA/ASC B651:23 as an additional project benchmark. That requirement can guide design or an existing-facility assessment alongside the code review. Record it in the project brief and consulting scope, including any limits on the areas or features to be reviewed. Other requirements tied to a particular owner or project must also be identified.

Keep the review basis clear in each finding

Consider a proposed washroom renovation. The project team first establishes the applicable code requirements for the work. If the owner has also commissioned a B651:23 review, the consultant assesses the agreed features against that benchmark. Each comment should identify its basis so the designer can distinguish an applicable permit requirement from an additional owner requirement.

A useful review register records:

The feature and drawing or site location being assessed.
The governing code provision or agreed standard, including its edition.
The observation and information needed to reach a conclusion.
The proposed response, responsible party and decision status.
The evidence required to confirm the item is addressed.

This approach also helps when a design changes. The team can revisit the affected findings without losing track of the requirements agreed earlier.

Use the benchmark to improve decisions

For new construction, review the basis while layouts and product selections can still change. For an existing facility, use the findings to develop a practical improvement program. Agree on priorities with the owner and identify where further design or investigation is needed before assigning construction budgets.

Accessibility also depends on everyday use. The Province’s accessibility guidance explains that the BC Building Code does not regulate furniture placement or building operation and management. Include operational observations when they are part of the commissioned scope, and assign them to the people who can act on them.

Scope an accessibility consulting assignment

Provide the address, building use, project stage, available drawings and owner objectives. Identify any requested CSA edition and whether the deliverable is a drawing review, site assessment, issue register or follow-up review. Agree on how unresolved issues will be handled with the design team and authority where required.

Noven’s Accessibility Consulting can be coordinated with Building Code Consulting. Request a proposal to establish the review basis and deliverables for your building.

Related insights

Technical references

References reviewed October 26, 2026. A project-specific assessment establishes applicable requirements; publication of a standard is not evidence of its adoption.