Why the OBO Returns Building Permit Plans (and How to Fix Them)

A returned set is rarely a rejection. It's a to-do list, and most of it is paperwork your designers can clear in days. Illustrative photo.

Short answer: the Building Official can hold back a permit for three reasons only, under Section 306 of the Revised IRR of PD 1096: errors in the plans, wrong information, or non-compliance with the Code. In practice the comments come from the same places again and again: sheets not signed and sealed (or carrying last year's PTR), setbacks and lot coverage that don't match Rule VIII, structural sheets with no computations or soil data, fire safety documents the BFP can't turn into an FSEC, and plumbing or electrical sheets missing a load schedule or septic detail. Most of it is fixable by the designers you already have. Under RA 11032 the office has 3, 7 or 20 working days per complete submission, depending on the class of application. A return isn't a complete submission, so plan on each one costing your designer's correction time plus another full evaluation (our reading of the law; see section 8).

Run the checklist below before you submit, or against the correction sheet you just got back. It flags the items most likely to bounce and estimates the working days to permit, with and without a resubmission.

1. What a "Return" Actually Is

Owners call it "na-reject", but legally most returns aren't rejections at all. There are three things that can happen to a permit application, and they carry different weight.

• At the counter. Under RA 11032, Section 9(a)(2), the receiving officer does a preliminary check and must immediately tell you about any missing requirement, and those requirements are limited to what's listed in the office's Citizen's Charter. A missing notarization or title copy should be caught here, not two weeks later.
• After technical evaluation. The sections of the OBO and the BFP evaluate the plans. Where something is deficient, JMC 2018-01, Section 6.1.14 says the applicant gets a comprehensive correction sheet and/or a notice of disapproval from the Zoning Officer, the OBO and the local BFP, stating all deficiencies. Quezon City's charter calls the same document a Letter of Instruction. You correct and resubmit. If it's still deficient, you get another one.
• Formal non-issuance. Section 306 of the Revised IRR lets the Building Official refuse, suspend or revoke a permit for errors in the plans and specifications, incorrect or inaccurate data, or non-compliance with the Code. The notice must be in writing and state the reasons. RA 11032 Section 9(b)(2) says the same thing from the other side: no application may be returned without appropriate action, and a disapproval comes with a formal notice of the reason.

The important word in JMC 2018-01 is all. A correction sheet is supposed to list every deficiency the evaluators found, in one go. If you fix everything on it and get a brand-new comment on a sheet that didn't change, that's worth a polite question at the desk.

2. The Usual Reasons Plans Come Back

JMC 2018-01 tells Building Officials to evaluate against a standard checklist that follows the Code and its IRR (its Annex 3a), and the BFP uses its own Fire Safety Checklist under the Fire Code RIRR. We haven't found a published, numbered list of "top reasons for return", so the table below is what we see in practice, sorted by the section of the office that raises it, with the rule behind each one.

Notice how many of these are clerical. Title copies, notarization, stamps and PTR numbers cost nothing to get right the first time and are the easiest items to lose a week on. The expensive ones are the last few rows of the architectural and structural sections, because they can mean redesign rather than reprinting.

3. Signatures, Seals and the PTR

Section 302(3) of the Revised IRR is specific about who signs what. The plans have to be prepared, signed and sealed over the printed names of the licensed professionals:

The one that used to cause arguments is the architectural set. For years some OBOs accepted floor plans and elevations signed by a civil engineer. That's settled now. In DPWH v. PICE and UAP v. PICE, G.R. Nos. 200015 and 205846, decided March 15, 2023, the Supreme Court reinstated the 2008 trial court ruling that upheld Section 302(3) and (4), and held that only registered and licensed architects may prepare, sign and seal the listed architectural documents: the vicinity map, site development plan, perspective, floor plans, elevations, sections, reflected ceiling plan, accessibility details and the fire safety documents among them. The Court denied the civil engineers' motion for reconsideration with finality on October 30, 2024, and DPWH told every Building Official to apply the rule in NBCDO Memorandum Circular No. 01, s. 2025, dated February 7, 2025. If your architectural sheets carry only an engineer's seal, expect them back.

The quieter problem is the title block. The IRR's model title block (Figure III.2) has fields for the PRC number and its validity, and the PTR number and date. Under Section 139 of the Local Government Code, the professional tax is paid annually on or before January 31, and the professional has to write the official receipt number on plans and designs. A set drawn in November and submitted in February often still shows last year's PTR. It's a one-day fix, but it's a return.

The application also needs one copy of the valid licenses of all the professionals involved (the PTR and the PRC ID), plus valid IDs of the applicant and of the lot owner if they are different people, under Section 8.2.1(c) of the Amended JMC No. 2021-01, which replaced the three photocopies JMC 2018-01 asked for. If one of your designers is slow to send theirs, that's the item to chase first.

4. Site Plan, Setbacks and Lot Coverage

Before anyone looks at the building, the line and grade section checks the lot. Under IRR Section 303(2) it verifies the lot plan against the OCT or TCT, checks easements and setbacks and the grades against roads and property lines, and confirms at least one side of the lot has direct access to a street or alley. A site plan copied from a subdivision brochure, with the house floating somewhere near the middle, won't get through.

Then the architectural section looks at how much of the lot you're covering. Table VIII.1 of the Revised IRR sets the maximum percentage of site occupancy by zoning. For a basic R-2 single-family lot it's 55 percent without a firewall, 60 percent with one; basic R-3 is 65 and 70. R-1 lots aren't in that table at all: the IRR sends them to the minimum yards in Table VIII.2. And the local zoning ordinance governs on top. Our setback requirements guide has the full yard tables and the common wrong numbers.

The other site item is the locational clearance. IRR Section 302(12)(a) requires one from the City or Municipal Zoning Administrator. Two exceptions in Section 303(1) are worth knowing: a project inside a development already permitted by HLURB or the Sanggunian doesn't need an individual one, and an alteration or renovation of an existing building submits its latest Certificate of Occupancy instead.

5. Structural Sheets

This is the section where a "small" comment can mean real work. IRR Section 302(5) asks for foundation plans, framing plans and details at not less than 1:100, and then two things owners don't always get from a cheap plan set:

• Structural analysis and design for all buildings and structures, except a one-storey, single detached structure with a total floor area of 20.00 m² or less. A two-storey house with no computations is incomplete, full stop. A reviewer who asks for them isn't being difficult.
• Boring tests, plus load tests where needed, for buildings of three storeys and higher, and soil exploration for lower buildings in areas with potential geological or geotechnical hazards, with the written report of the civil or geotechnical engineer, including the design bearing capacity, submitted with the permit application. The structural code itself goes further than the IRR: NSCP 2015 Section 303.1 calls for an exhaustive geotechnical study at two storeys or more. Our soil boring test guide covers what that costs.

Section 302(5) also lists a seismic analysis. The fastest way to get a structural comment is general notes that don't match the site. NSCP 2015 has only two seismic zones: Zone 2 (Z = 0.20) for Palawan except Busuanga, Sulu and Tawi-Tawi, and Zone 4 (Z = 0.40) for everything else. It has no wind zones either; the basic wind speed comes off one of three maps chosen by occupancy category. Plans recycled from another province, or notes still quoting a pre-2015 wind zone, are an easy catch for the reviewer. Our NSCP seismic design guide explains what should be in those notes.

If the structural set came back because the computations were never done, that's not a correction, it's the design. AEDO's 3-working-day structural design covers it: NSCP 2015 analysis, sealed plans and a design report, ₱7,500 up to 150 m² and ₱50/m² above that up to 500 m², starting once your architectural plans are in.

6. The BFP Side: FSEC and FSCR

The Building Official doesn't review fire safety alone. IRR Section 303(10) sends a set of plans to the City or Municipal Fire Marshal, who reports within five working days of referral, and failure to act within that period means the plans are taken to conform to the Fire Code. Under the Fire Code's 2019 RIRR, Rule 9, Division 1(C), the Fire Marshal issues a Fire Safety Evaluation Clearance (FSEC) as a prerequisite for the building permit. RA 11032 later capped it: Section 12(a) says issuing an FSEC shall in no case take longer than seven working days.

How the BFP evaluates, from RIRR Section 9.0.2.1: a Plan Evaluator checks the plans using a Fire Safety Checklist, and the Fire Marshal then issues either the FSEC or a Notice of Disapproval. Two things tend to trip owners up:

• The FSCR. Section 9.0.2.1(C) says no building plan shall be evaluated without a Fire Safety Compliance Report where Division 3 requires one, and Section 9.0.3.1 applies it to buildings that, by use, size and height, must install a wet standpipe, automatic fire suppression or automatic detection and alarm. It's signed by the Engineer or Architect-of-Record and a BFP-accredited Fire Safety Practitioner, and comes with three sets of plans. A small house won't need one. A mid-size commercial building often does.
• The fire safety sheets. IRR Section 302(4)(e) lists them under the architectural documents: an evacuation layout for each floor with extinguishers, alarm, emergency lights and signs, plus fire-exit and fire-resistive details.

Don't treat the FSEC as optional paperwork. RIRR Section 12.0.0.4 B.8(c) sets an administrative fine of ₱37,500 to ₱50,000 for an FSEC not secured before construction. Our FSIC guide picks the story up at the other end, when the building is finished.

7. Electrical, Mechanical, Plumbing and Accessibility

These sheets are shorter, which is exactly why they get rushed. What the IRR asks for:

• Electrical, Sec. 302(6): location and site plans, legend, general notes, the electrical layout, a schedule of loads with the total kVA, a design analysis and a one-line diagram. The load schedule and one-line diagram are the two most often missing. Our electrical service sizing guide shows how the schedule is built.
• Mechanical, Sec. 302(7): layouts at not less than 1:100, sections, duct details and equipment foundations. Under 302(7)(j), machinery of at most 14.9 kW can be signed by a licensed mechanical engineer, but that relief does not cover central, split or packaged aircon, elevators, pressure vessels or fuel and gas piping.
• Plumbing, Sec. 302(9): location and site plan, plumbing plans and details at not less than 1:50, legend, isometric drawings, design analysis and cost estimates. The plumbing section checks against the Plumbing Law, RA 1378, under Sec. 303(8). A septic tank drawn on the site plan that doesn't match the plumbing layout, or no septic detail at all, is a common comment. Our septic tank sizing guide covers the National Plumbing Code side.
• Accessibility: IRR Sec. 302(4)(a)(viii) lists accessible ramps, stairs, entrances, comfort rooms, switches, signage and reserved parking among the architectural details, and Sec. 302(4)(c) and (d) want plans of all accessibility facilities. For a shop, clinic or any building the public uses, missing BP 344 details are a return, and our BP 344 guide explains what the 2024 IRR asks for.

Changing the use of an existing building has its own trap: the application needs the latest Certificate of Occupancy, and the new use may put you in a different occupancy group. See our change of occupancy guide. For the separate electrical, plumbing and mechanical permit forms that ride along with the building permit, see ancillary permits.

8. How Long a Resubmission Takes

Three layers of rules set the clock, and they don't all say the same number.

JMC 2018-01 used to class a single-dwelling house of up to three storeys under 1,500 m² as a simple application. The Amended JMC No. 2021-01 (signed December 2021) redrew the classes in its Section 6. Simple is now a short list (§6.1): private garages up to 90 m², carports, sheds, agricultural buildings, fences over 1.80 m, tanks and towers, repairs that don't change the approved plans, demolition of a single residential structure up to 300 m² and three storeys, signage, and stand-alone equipment permits. Complex (§6.2) includes interior renovations, changes of occupancy, multiple-unit residential houses such as rowhouses and townhouses, a single detached residential house of up to seven storeys, and commercial buildings, warehouses and markets of up to nine storeys. Highly technical (§6.3) covers taller buildings, hospitals and other Group D occupancies, large assembly buildings and special structures. Section 8.4.1 then sets 3, 7 and 20 working days for the three classes, including the BFP's FSEC time, and Quezon City's charter applies the same figures. So a house is a 7-working-day application. Check your own LGU's charter; it's supposed to be posted at the city or municipal hall and downloadable online.

The part owners miss is that the clock runs from a complete submission. A returned set isn't complete, so when you resubmit, you're back at the start of an evaluation period. That's our reading of Section 9's wording, and it matches the Quezon City charter, where corrected documents go through evaluation again. So the real cost of a return is:

your designer's correction time + another full evaluation period

For the calculator's default case (a house, complex class, with an old PTR, setbacks not checked and a septic detail nobody is sure about), that's about 8 working days if nothing comes back, and about 21 working days with one resubmission. The correction days in that estimate are ours, not the law's.

Two more rules are worth knowing if the office sits on your file. RA 11032 Section 10 says an application that isn't approved or disapproved within the processing time is deemed approved, provided all required documents were submitted and all fees paid; the acknowledgment receipt and official receipt then serve as the permit. That condition matters: a file already flagged as incomplete doesn't qualify. And if the permit is refused, IRR Section 307 lets you appeal to the Secretary of Public Works and Highways within 15 days of receiving the notice. The Secretary decides within 15 days, subject only to review by the Office of the President.

Fees are a separate question from time; our building permit fee calculator works those out from the IRR schedule.

9. Do You Need a New Designer?

Usually not, and it's worth thinking twice before you switch. IRR Section 304(5)(b) makes the design professionals who signed and sealed the plans responsible for their comprehensiveness and correctness under the Code and its referral codes. The comments on your correction sheet are their comments to fix, and most are paperwork or small drafting changes.

A change of designer makes sense when:

• the original designer can't be reached or won't correct the work;
• the structural set was never really designed, just drawn, and there are no computations behind it;
• a discipline is missing entirely, like a house whose "complete plans" had no plumbing or electrical sheets;
• the plans were bought or copied from another project and don't fit your lot.

On that last point, a plan drawn for another lot fails the site checks almost by definition: the vicinity map, site development plan, setbacks and line and grade are all specific to your title. Whoever adapts it has to sign and seal what they revise, which means taking professional responsibility for it, and a careful designer will want to check the structure, not just re-stamp it. Budget for real design work, not a reprint.

If you do switch, get the returned sheets and the correction sheet together, and ask the new team which sheets they'll re-sign. Every sheet they change carries their seal from then on. And once the permit is out, the same discipline applies to changes during construction: IRR Section 304(5)(c)(v) requires changes to be submitted and an amendatory permit issued before that work starts.

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