Automatic Sprinkler System for Existing High-Rise Buildings (2025 San Francisco Fire Code - Effective January 1, 2026)

In 2022, the City adopted Section 1103.5.4 of the San Francisco Fire Code, requiring certain existing residential high-rise buildings to install automatic sprinkler systems. You previously received notice of the original requirements under the 2022 San Francisco Fire Code. Through the triennial adoption of the 2025 Fire Code, Section 1103.5.4 has been amended.

This website summarizes what remains in effect, what has been amended in 2025, and how these updates apply to your building moving forward.

1. What Remains in Effect

The following requirements from the 2022 Fire Code remain unchanged.

  • Existing residential high-rise buildings are required to install an approved automatic sprinkler system if:
    • The building has an occupied floor more than 120 feet above the lowest level of fire department vehicle access; or
    • The building has occupied floors between 75 and 120 feet above fire department vehicle access and lacks either:
      • Two interior exit stairways enclosed with fire-resistance-rated construction, or 
      • A compliant fire alarm system with required smoke detection coverage.

(2025 Fire Code Section 1103.5.4.)

  • The retrofit process continues to proceed in three phases:
  1. Step 1 – Permit application submission: The owner must submit professionally prepared permit drawings and a permit application to the Department of Building Inspection. (See 2025 Fire Code Section 1103.5.4.5.1.)
  2. Step 2 – Water supply and riser installation: The owner must install the sprinkler riser and connect it to the approved water supply connection. (See 2025 Fire Code Section 1103.5.4.5.2.)
  3. Step 3 – Full system completion: The owner must complete the system piping, sprinkler heads, and electrical monitoring. (See 2025 Fire Code Section 1103.5.4.5.3.)
  • The maximum compliance period remains 12 years.
  • All associated fire alarm and monitoring components must comply with the San Francisco Fire Code, the San Francisco Electrical Code, and NFPA 72.

The Fire Marshal retains authority, as provided in the Code, to evaluate alternate methods and consider time extensions where appropriate.

2. What Has Changed - 2025 Amendments

Pursuant to amendments to Section 1103.5.4, the following requirements have been modified or added as follows:

  1. Established Calendar Deadlines

The previous compliance schedule tied to the original effective date has been replaced with the following compliance deadlines:

  • Step 1: Permit application submission: January 1, 2032 (Previous Deadline - January 1, 2027)
    • Step 2: Water supply and riser installation: January 1, 2034 (Previous Deadline - January 1, 2031)
    • Step 3: Full system completion: January 1, 2035
    • Clarified Hardship Considerations

The amended Section 1103.5.4.4 now expressly provides that, when evaluating undue hardship, consideration may be given to:

  • Financial hardship; and
  • Whether compliance would result in displacement of residents.

The SF Board of Supervisor's Ordinance No 74-26, FILE NO. 260216 establishing the Technical Advisory Council (TAC) was approved by the Board of Supervisors on April 21, 2026 was signed by the Mayor on April 30, 2026, and became effective on June 1, 2026.

The TAC is tasked with advising the Board of Supervisors, the Mayor, and the Fire Department on the evaluation of requests for alternate methods, waivers, and compliance extensions under Fire Code Section 1103.5.4. The committee will also develop definitions for key Fire Code terms related to alternative compliance and hardship.

The TAC consists of 11 voting members representing property owners, tenants, homeowners’ associations, design and construction professionals, designated representatives from City agencies, and a member of the Board of Supervisors. Members serve at the discretion of their appointing authorities, and the Fire Department provides administrative support.

The committee is required to review all submitted materials and issue findings and recommendations within 90 days of its first meeting. The inaugural meeting will be scheduled by the Fire Chief. During its initial 90-day period, the TAC must meet at least twice monthly and thereafter at least once per month. Unless extended by ordinance, the committee will sunset one year after its first meeting.

For more information on the approval process of the TAC, please the link below.

San Francisco Board of Supervisor TAC Approval Process

 

  1. Exemption Expiration

The exemption for certain Residential Group R-2 occupancies (classified as R-1 prior to 2008) now expires on January 1, 2035.

3. Commitment to High-Rise Safety

These sprinkler retrofit requirements reflect San Francisco’s long-standing commitment to strengthening high-rise life-safety standards and protecting residents in multi-story buildings.

Failure to meet required deadlines may result in enforcement action as provided in the San Francisco Fire Code.

The San Francisco Fire Department remains committed to:

  • Promoting life safety for residents and emergency responders.
  • Providing clear and consistent compliance guidance; and
  • Working with building owners to evaluate reasonable pathways to compliance.
  • Reviewing hardship requests on a case-by-case basis consistent with the amended Code.

Our objective is to ensure that residential high-rise buildings meet established safety standards while recognizing the practical considerations associated with implementation.

Questions may be directed in writing to:

San Francisco Fire Department
Bureau of Fire Prevention
Attn: Captain Tracy O’Keeffe
698 2nd Street, Room 109
San Francisco, CA 94107

Main:  415-558-3300

Direct:  415-558-3379

2026 San Francisco Fire Code Section 1103.5.4