What a self-certified permit proves
A self-certified permit proves that a private licensed professional signed a statement saying the drawings comply with the code. It does not prove a City reviewer agreed with that statement, because no City reviewer read the drawings.
Self-certification is one of the routes by which a building permit is issued in Chicago. An Illinois-licensed architect or structural engineer, registered with the Department of Buildings as a Self-Certification Professional, certifies code compliance in place of the Department's own review. The Department's public page states the position without euphemism: because the registered professional certifies compliance, the Department's plan reviews are skipped, and the professional must take full responsibility for code compliance.
That is a defensible way to run a permit system. It is also a completely different evidentiary object from a permit a City plan reviewer examined, and the two are not distinguishable on the face of a permit number. The difference lives in one field of the published data and nowhere else a reader is likely to look.
Everything below describes the program's Amended Rules and Regulations as published December 20, 2017 and effective January 1, 2018. A later version with a January 2020 effective date is posted by the City and could not be retrieved, and the Department's implementation memorandum for the recodified codes anticipated new self-certification rules taking effect in 2020. Treat what follows as the rules as published in 2018, which may since have been superseded.
What the professional actually certifies
Under Rule G.1 of the 2018 rules, the certifying professional makes seven certifications. They are worth reading closely, because every one of them is a private statement rather than a City finding:
- that the professional meets the program's eligibility requirements;
- that the project is eligible under the rules;
- that the work shown in all submitted documents — including documents sealed by others — will conform to the Building Code, the body of law setting construction standards for buildings in the city;
- that the documents were prepared to the applicable standard of care for architecture in Illinois;
- that all information in the application is true and correct;
- that the professional will meet the program's ongoing obligations;
- that the professional understands the Commissioner relies on these certifications, and that the permit is subject to inspection and audit.
The third is the one a records reader should sit with. The certification reaches drawings the certifying professional did not prepare and did not seal. One signature covers the structural, mechanical and plumbing sheets produced by other hands.
The rules also bound the program by occupancy, height and area: detached single-family up to four stories; multiple dwellings up to four stories within stated unit limits; single-tenant small assembly, business and mercantile uses up to two stories and 10,000 square feet; business or mercantile with up to four tenants up to four stories and 30,000 square feet; and mixed occupancy up to four stories and 30,000 square feet. Disqualifiers include any increase in the number of dwelling units in an existing building, assembly occupancies with an occupant load over 299, new construction or additions over 30,000 square feet, more than four stories, more than 55 feet, modular construction, and work in existing buildings over 80 feet without written pre-approval.
What the City still checked
Self-certification removes the Department's plan review. It does not remove everything, and a reader who treats a self-certified permit as entirely unreviewed is overcorrecting.
Under Rule J of the 2018 rules the City still reviewed:
- zoning compliance, by the Zoning Administrator and the Department of Planning and Development — the City department responsible for zoning administration, landmarks and development review;
- the Stormwater Management Ordinance, where applicable;
- the Chicago Department of Transportation's Office of Underground Coordination, where applicable.
The Department also checked compliance with the program rules themselves, with one opportunity to correct minor defects. A debt clearance certificate from the Department of Finance was required, and a structural peer reviewer's report where the rules' structural table applied. Under Rule V.1, all self-certified permits are conditional and subject to field inspection and post-issuance audit.
So the field inspection regime is unchanged by self-certification. What changed is who read the drawings before the permit issued — and, separately, Chicago's field inspections are themselves requested by the permit holder rather than initiated by the City, which is a weakness this route inherits rather than creates.
The audit nobody can point to
The program's own answer to the obvious objection is audit. Under the 2018 rules, audits may be random or judgmental at the Commissioner's discretion, may cover one, several or all disciplines, and occur within 12 months of permit issuance or, where the work is incomplete, before completion as evidenced by passing final inspections.
No audit rate is published anywhere. The rules state no audit percentage. The Department's public page on the program states none, does not list excluded project types, and does not say what inspections the City still performs. No audit result, failure rate, disciplinary tally or enforcement statistic for the Self-Certification Permit Program was located in any primary source. The Office of Inspector General's 2022 audit of the Department's permit inspections process does not mention self-certification at all.
That absence is the finding. It is not a gap in this page's research that a better search would close; it is a program whose outcomes do not appear to be published. Anyone who tells a buyer that some specific share of self-certified permits is audited, or that audits turn up problems at some particular rate, is quoting a figure that does not exist in the public record. The honest statement is that the program's results are not publicly measurable, and have not been for the whole period in which the public data has been available.
The rules are posted as the Department's Self-Certification Permit Program Amended Rules and Regulations, effective January 1, 2018.
The consequences fall on the professional, not the building
Where the program does have teeth, they bite in a direction that does not help a reader assessing a building. The 2018 rules carry a point system applied to the registered professional: one point for submitting an ineligible project, two for substantial defects found before issuance, two for a false statement in an application, two for a non-compliant condition, five for a non-compliant condition posing serious risk, and five for failing the program's ongoing obligations. Five points within 365 days, or ten within a registration period, supports suspension; ten within 365 days, or twenty within a registration period, supports suspension or revocation of the professional's registration.
Separately, where a code violation poses serious risk, or a false statement was made, the Department may issue a stop work order or revoke the permit.
Two things follow for a records reader. First, the sanction attaches to a person, and there is no published roster of accumulated points, so the professional's record is not something the public data exposes. Second, a revoked permit is excluded from the published Building Permits dataset, which means the enforcement outcome that would most concern a buyer removes the record rather than annotating it.
Reading a self-certified permit in the data
The route is recorded in the REVIEW_TYPE field of the City's Building Permits dataset, which the City defines as the process used to review the permit application. That field is the only place a self-certified permit is distinguishable from one the City reviewed. Everything else on the record — the work description, the fees, the issue date, the contractor fields — looks the same.
The Department's Self-Certification Permit Program page adds one structural detail worth knowing: permit expediters cannot submit self-certified applications, which must be filed by the certifying professional through the Department's electronic plan system. Whatever else is true of such a permit, a named licensed professional stands behind it and can be identified.
One last caution on authority. The 2018 rules state they were adopted under Municipal Code sections numbered in the pre-recodification scheme, including a Title 13 section. Chicago recodified its construction codes, with the new codes becoming mandatory for most permit applications on August 1, 2020, and the administrative provisions now sitting in Title 14A — which authorizes the building official to designate by rule that certain work, expressly including self-certified permit applications, proceed under the current building code. The old section numbers in the 2018 rules are not current law, and whether they survive under new numbers was not confirmed. The substance of the program is documented. Its citation trail is not current.