Under California Government Code section 65913.3, added by AB 2234 in 2022 and amended since, a city or county must decide within 15 business days whether an application for a post-entitlement phase permit on a housing development is complete, and must then approve it or return a full set of comments within 30 business days for projects of 25 units or fewer, or 60 business days for 26 units or more.
This page summarizes the statute for agency staff. It is not legal advice. Read the statute and consult your agency’s counsel.
What is a post-entitlement phase permit?
It covers the nondiscretionary permits and reviews needed to begin construction of a development that is at least two-thirds residential after entitlements are complete. That includes building permits and the interdepartmental reviews required to issue them, minor or standard offsite improvement permits, demolition permits, and minor or standard grading permits. It also includes all building permits issued under Title 24 or a local building code for the construction, demolition or alteration of buildings (§65913.3(k)(3)).
What does Gov. Code 65913.3 require?
| Requirement | Deadline or rule | Source |
|---|---|---|
| Publish a list of what a complete application must include | Posted on the agency website; a revised list does not apply to permits already pending | §65913.3(a)(1), (a)(3) |
| Post examples of complete, approved applications | At least five housing types, including ADU, duplex, multifamily, mixed use and townhome | §65913.3(a)(2) |
| Decide completeness and notify the applicant | 15 business days after receipt | §65913.3(b)(1)(A) |
| If incomplete, list the incomplete items and how to fix them | Limited to items on the published list | §65913.3(b)(1)(B) |
| If no timely completeness determination | Deemed complete, if the application states it is for a post-entitlement phase permit | §65913.3(b)(3) |
| Approve, or return a full set of comments with a comprehensive request for revisions | 30 business days after completeness (25 units or fewer); 60 business days (26 units or more) | §65913.3(c)(1), (c)(2) |
| If noncompliant, list the noncompliant items and how to remedy them | With the determination | §65913.3(d) |
| Appeal | Final written determination within 60 business days (25 units or fewer) or 90 business days (26 or more) | §65913.3(e)(2) |
The statute allows exceptions, including written findings of a specific, adverse impact on public health or safety, and tolling while an outside entity reviews the application (§65913.3(c)(4), (c)(5)). It does not limit how much feedback an agency may give (§65913.3(h)).
What happens if a local agency misses the deadlines?
The statute says that if a local agency fails to meet the time limits in the section, “it shall be in violation of Section 65589.5,” the Housing Accountability Act (§65913.3(f)).
Did SB 489 move these timelines into the Permit Streamlining Act?
No. The post-entitlement timelines remain in Gov. Code §65913.3, which was most recently amended by AB 301 (Stats. 2025, ch. 488), effective October 10, 2025. The Permit Streamlining Act’s definition of “development project” expressly excludes a post-entitlement phase permit as defined in §65913.3 (Gov. Code §65928(b)(2)).
SB 489 (Stats. 2025, ch. 518) changed the Permit Streamlining Act for the earlier, entitlement stage of housing projects. For example, it requires agencies to publish online, for each type of housing approval, the list of required information and the criteria used to decide completeness (Gov. Code §65940(d), effective January 1, 2026). Separately, the Act now treats a housing development project that requires an entitlement as a development project whether the entitlement process is discretionary or ministerial (§65928(b)(1)(B)), and sets 60 days from a complete application for projects subject to ministerial review (§65950(a)(6)).
How can a review tool help staff meet these timelines?
A review tool does not make an agency compliant, and it does not decide anything. It can shorten the reading and drafting:
- Completeness against the published list. CrossBeam Permits compares the package with the agency’s own published submittal list and drafts the notice of incomplete items, limited to that list, for staff to review.
- A full set of comments. It reads the full plan set against Title 24 and the agency’s local amendments and drafts findings, each citing a code section and a sheet, so staff can assemble the comprehensive request for revisions the statute calls for.
- Backchecks. On resubmittal, it checks each prior item and reports which appear resolved, plus changes elsewhere in the set.
- Applicant pre-check. An agency can offer applicants a pre-check before submittal, so fewer incomplete packages start the clock.
Staff make every determination, and the agency remains responsible for meeting the deadlines. CrossBeam Permits is available to every California city and county.
We work with agencies anywhere
CrossBeam Permits works with cities, counties and agencies anywhere in the country, under whatever timelines their state sets. See also California ADU 60-day timeline and Washington SB 5290.
Sources
Facts and sources checked October 30, 2026.
- California Government Code §65913.3 (as amended by Stats. 2025, ch. 488, AB 301, effective October 10, 2025) (accessed 2026-10-30)
- California Government Code §65928 (as amended by Stats. 2025, ch. 650, SB 158) (accessed 2026-10-30)
- California Government Code §65940 (as amended by Stats. 2025, ch. 518, SB 489, effective January 1, 2026) (accessed 2026-10-30)
- California Government Code §65950 (accessed 2026-10-30)
CrossBeam Permits is operated by Onboard Dot AI LLC, Huntington Beach, California. Not affiliated with Crossbeam, the partner-ecosystem software company at crossbeam.com.