To Permit or Not to Permit, That Is the Question: All You Need to Know About Permitting for Access Control and CCTV

The idea that “one-for-one” replacements don’t require permits is outdated—most electrical work, including low-voltage systems, legally requires permits, plans, and licensed contractors. Skipping this process can lead to costly, long-term violations, so compliance is essential for both safety and liability.

The belief that “one-for-one” replacements don’t require permits is outdated and incorrect, stemming from pre-2000 practices in Honolulu when low-voltage systems like fire alarms, CCTV, and access control were loosely regulated. Today, under Revised Ordinances of Honolulu Chapter 18, nearly all electrical work—including these systems—requires a permit, with only a narrow exception for minor repairs under $2,500. Most installations or upgrades in multi-unit or commercial buildings require engineered plans and licensed contractors, with stricter rules depending on whether new conduit or equipment is added. These regulations exist to protect public safety and ensure qualified professionals perform the work. Ignoring permit requirements can lead to serious, long-term consequences for property owners, including costly violations with no statute of limitations, making compliance the far safer and smarter choice.
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To Permit or Not to Permit, That Is the Question: All You Need to Know About Permitting for Access Control and CCTV

We hear it all the time: “You don’t need a permit; it’s a one-for-one change replacement.” This is not a true statement, but where did it come from? Why does it persist in the marketplace?
 
Back in the olden days, circa 1999, the Honolulu Fire Department was allowing “one-for-one” replacement of fire alarm systems without permits. In those “good old days,” low-voltage systems were essentially ignored by the county inspectors. Camera systems, network cabling, and access control systems were installed without permits. But as the old guard retired and new energetic reviewers and inspectors took over, they started reading and applying the sections of the code that required permits for these systems. Toward the end of the second decade of the new millennium, these systems were required to be included in the drawings produced by engineers. The problem? People in the field were still adhering to the old unwritten rules:
1. It is low-voltage.
2. It is a one-for-one replacement; therefore, a permit is not required.
 
Nothing could be further from the truth.
 
The Revised Ordinances of Honolulu Chapter 18 dictates which projects require permits. This section states that all electrical work requires a permit. There are a few exceptions to this mandate, but most are for industrial applications and single- and two-unit dwellings. The only exception that applies to CCTV (closed-circuit television) and access control systems is “Repair work performed by a licensed electrician valued at $2,500 or less in the aggregate in any 12-month period, and that does not involve service entrance equipment.” So, there you have it.
 
You might be thinking, “What a hassle!” Well, maybe. But legitimate contractors will want to comply with the law. Plans will be required for projects involving these systems in multi-story residential buildings. Also, because multi-unit residential and commercial buildings have the potential for work in one space to affect other spaces, a licensed electrical engineer is required to create the drawings and a licensed electrical contractor is required to perform the installation.
 
There are four types of licenses which may be applicable to the systems discussed herein.
A C-15 license is for an electronic systems contractor; a C-15a license is for fire and burglar alarm systems; and a C-15b license is for telecommunications contractor.
 
A C-13 license is an electrical contracting license. The C-13 license includes all the C-15 licenses. The C-15 licenses allow for the installation and maintenance of CCTV and access control systems, provided there is no installation of conduit required. Only a C-13 licensed contractor may install conduit.
 
Practical application of the ordinances and statutes looks like this:
1. New installation of a CCTV or access control system where new conduit is required: Plans from a licensed engineer are required to acquire a permit. A C-13 electrical contractor is required for installation.
2. New installation of a CCTV or access control system that utilizes existing conduit and wiring: Plans from a licensed engineer are required to acquire a permit. A C-13 electrical contractor or C-15 electronics contractor is required for installation.
3. Replacement of cameras or other electronics with like devices with a total cost of $2,500 or less: No plans or permit required. A C-13 electrical contractor or C-15 electronics contractor is required for installation.
4. Installation of the additional camera or cameras of any value: Plans from a licensed engineer are required to acquire a permit. A C-13 electrical contractor or C-15 electronics contractor is required for installation, depending on whether or not new conduit is required.
 
Clearly, the rules for installations requiring permits are quite strict. The purpose of the strictness is to protect the public from unscrupulous and unlicensed individuals who unknowingly put the public at risk when they do not follow the code. When following the law, there are multiple levels of protection for the building owners and the public who use the facility.
 
On the other hand, you may be tempted to say, “This is ridiculous,” and choose to go without proper permitting. This is an increasingly treacherous path to take. With social media and the tendency for people to stick their noses in other people’s business, it is very likely that a complaint will be made against the building owner. It will be the building owner’s responsibility to resolve the permitting issue forever. There is no statute of limitations on permit violations. They can come back to haunt you anytime and often at a far greater cost than what the original installation would have cost.
 
So, the next time you hear someone say, “You don’t need a permit for that,” beware; that statement is more likely to be wrong than right. Be safe, always get permits when they are required, and use properly licensed installers. To permit or not to permit is no longer the question – the real question is whether you’re willing to risk your project, your reputation, and your pocketbook by choosing the wrong answer.