What is it exactly that makes that room a bedroom? The question has come across my email enough, and actually I think I even posted on it at some point. Well, it’s resurfaced and maybe time to hash it out, as the opinions on what makes a room a bedroom are anything but concrete.

The initial question:

A few months ago an email was circulated as to what defines a bedroom. There were several responses, but if I remember correctly a bedroom does not have to have a closet to be a bedroom…

And the varying replies from various real estate agents:

-My understanding is it technically must have a window – ideally with a means of egress
-My understanding is two methods of egress. A door, and another door or a window or some way to get out in the case of an emergency. No closet necessary.
-Operable window, that a person can fit through AND the minimum size is 70 square feet, where the minimum for one of the dimensions is 7 feet.
-I believe that HUD requires a closet in order to count it as a bedroom for financing purposes. A lender could probably clarify that.
-I’d suggest using the International Uniform Building code that refers to a specific size of window based on square footage of BR. It needs to have a door and a window and the window has to be the right proportion. Read More.
-The Building Code requires an operable egress window with minimum size requirements as [the other agent] indicated. In addition the window needs to be sized for light and air requirements. If I remember correctly it is 10% of the floor area. A closet is not a requirement to satisfy the building code, but it may be a HUD requirement for financing, as [another agent] mentioned.

Perhaps the most accurate answer?

1. The first bedroom must be at least 120 square feet.
2. If your first bedroom is at least 120 square feet, you get to call your second bedroom a bedroom if it’s at least 70 square feet with 7’ on a side.
3. Required natural light and air: 8% of floor area of natural light, and 4% of floor area of air (operable window). A traditional double-hung window can cover both bases, because when it is open, it provides half the air as natural light.
4. Minimum clear headroom of 7’-6”
5. You need two means of egress. One may be a window. If the second is the window, fire department requires minimum area for personnel access of width 20”, minimum height 24” with net clear opening minimum of 5.7 square feet.
6. A closet is required.

And the first comment from that thread:

What you’ve written here is not entirely correct – I believe you may be conflating Realtor’s rules-of-thumb with actual Code requirements.

1) Sort of. Any habitable room (Living Rm, Dining Rm, etc) can be larger than 120 SF (2007 CBC SEC 1208.3)
2) Correct. Minimum Habitable room size (includes bedrooms) is 70 SF, 7′ minimum width (2007 CBC SEC 1208.3 & 1208.1)
3) These are correct window areas for required natural light (8% floor area) and ventilation (4% floor area), but neither is required if sufficient artificial light and mechanical ventilation are supplied (2007 CBC 1203.4.1 & 1205.3).
4) Correct – Minimum ceiling height for Habitable rooms is 7′-6″, however it is 7′-0″ for bathrooms, storage, kitchen, laundry (2007 CBC 1208.2).
5) Sort of. Only one exit (Means of Egress) is required, the other is an Emergency Escape & Rescue requirement. This is not a Fire Department requirement, it is a California Building Code requirement (SEC 1026.1)
6) Wrong. No closet is required by any State or Local code (Building, Housing, Health or otherwise).

So there you have it…the jury is clearly still out on this one. My advice, get used to living in closets if you’re living in San Francisco.


  1. I’m not sure if the height of 7’6 is correct, if that’s so then many bedrooms in SoMa lofts are no longer legit, for example my unit is a 2 bed/2 bath, and my bedrooms are only 6.75 feet tall. (built in 2002) My purchasing paperwork clearly states that it’s a 2 bed/2 bath.

    1. If memory serves, a lot of SOMA lofts were built by exploiting a live/work building code loophole in order to get condos built in areas a not zoned specifically for residential housing. I could be wrong, but perhaps there are variants that could apply to ceiling heights built in SLI, UMU, and RH- (etc.) zones?

  2. Recall that the short-lived live-work ordinance (under which that SOMA loft was likely built) allowed ceiling height of 6′-6″ min. under or on a mezzanine in addition to many other short cuts that developers exploited. Your bedrooms are probably on a mezzanine.

    Also, what the purchase paperwork says and what the building code says may be different.

  3. I believe you may be conflating Realtor’s rules-of-thumb with actual Code requirements.

    Conflating? Correct. Which is entirely appropriate here. Is the original question about how to build a compliant structure? Or does the question pertain to the selling of a property and the ability to accurately describe the dwelling? If building a new space or remodeling an existing space, then citing the current building code is appropriate. If the goal is to accurately describe a listing for a property (or to debate the accuracy of a listing) then the current building code may not be appropriate.

    I suspect the original question has more to do with listings than with satisfying city inspectors. And it seems like this is a much more grey area. My 1906 home has stairs that are definitely not code-compliant. So, do I not have a 2nd story? The ceiling height upstairs (before our remodel) was slightly north of 6′ but clearly that’s where two of the bedrooms were located when we purchased it. (It was not listed as a “zero bedroom”.)

    I could be wrong but I think that some things get grandfathered in (e.g. my previously squatty bedrooms that were original to the home) but if I convert my basement into a new bedroom today and the ceilings are only 7′ tall (and I don’t get a permit) then I probably have to claim that space as a “bonus room” or specifically call out that it’s “unwarranted”.

    It may seem counterintuitive that you could have to 6′ tall bedrooms that are “legal” and a 7′ tall bedroom that’s “unwarranted” but (to the best of my knowledge) you are trying to represent what was the legal intended use of the space at the time that it was created. Feel free to correct me if I’m wrong, but I’d assume that the RE gurus here could chime in?

  4. I would enjoy seeing an appraisal that includes a room that was less than 70 sqft with out a closet or door or window that called said room a bedroom.

    The question came to a Realtor: an incredible amount of homes purchased on the CA coast are financed; institutional financing requires an appraisal; so wouldn’t they be the ones to give a practical answer? Is there not a price difference between a 1 bed and den/office, and a full 2 bed?

    Building codes are for minimum safety and habitability, not practicality or finance-ability. So code isn’t a great yardstick when talking to the bank. They look for the full meter stick. (IOW more than code.)

  5. Great post, and an often-debated topic. I hear this question from clients all the time and we seem to have a standard response in my office. A room must have “a closet and an egress window” to qualify as a bedroom. But with many of the old Victorian homes we have here in Breckenridge, I’m not sure if that 70 sf requirement would cut it. I’ll check with our building department to see what they say.

  6. It also cannot be accessed through another bedroom. That’s why all these rooms stuck on the back of Sunset District houses have to be called Sunrooms and not bedrooms. Because you have to walk to a bedroom to get to them.

  7. Often debated, indeed! In NC (or anywhere else, I believe), a bedroom does NOT have to have a closet to be called a bedroom. However, it must be accessible from inside the home, be heated by conventional means, and have egress window: ICBO: The Uniform Building Code, Chapter 3, Section 310.4 (1999)
    Sill height shall not exceed 44 inches above the floor.
    Minimum net clear opening shall be 5.7 square feet; exception – grade level windows may have a minimum clear opening of 5 square feet.
    Minimum net clear opening height shall be 24 inches.
    Minimum net clear opening width shall be 20 inches.
    THis is for existing homes; new building codes differ a bit. Also, there are no minimum square footage requirements, but ceiling height, to be counted in square footage, must be 7′. Additionally, in dormered or slope ceiling rooms, you can count square footage that is only up to 5′ IF main part of room has ceiling height of 7′ or greater. This last is true for calculating all rooms’ square footage.
    Moving this conversation to real estate reporting, one *should* disclose that a bedroom does not have a closet if that is so, or disclose that you have to walk through one bedroom to get to another. It should be noted, however, that real estate is state-governed, and these rules will likely vary from state to state or even from region to region.

  8. What bugs me in SF is the taking the living rooms and dining rooms and just calling them bedrooms – specially when there are door issues. So I would like to add that one. A REAL door (not a french door) that LOCKS.
    I know it brings nightmares … but http://www.610rhodeisland.com/ for me doesn’t have any bedroom! If I have to hear the kids jumping on their beds, it’s not a bedroom!

  9. I am working on an adaptive reuse project where we are laying out apartments with interior bedrooms (no windows). I am not in San Fran, nor in California for that matter. But in my search to determine if this is possible I found this web site and read this article.

    I started this project with the opinion that a bedroom required a window. But from a search thru the code sections, I now am of the opinion that it is possible to qualify a room as a bedroom with out a window. I have reviewed the 2009 IBC for this determination. This code is different than the 2009 IRC.
    (The existing building is running this train. If it were new construction, we would revise the building foot print to allow for all bedrooms to have a window).

    Summary of my research,
    1 and 2 family building code, emergency escape and rescue IS required from sleeping rooms, basements and habitable attics, ALWAYS. The opening can be a window or door which leads directly to the outside with a path to a public way and needs to be of specific sizes.
    Multi family units however seem to be able to have interior bedrooms with no access to the exterior.

    Research summary below.
    For 1 and 2 family dwelling units, 3 or less stories in ht, (R-3 use group) using the 2009 IRC the emergency escape and rescue door/window IS always required, NO EXCEPTION. But it seems it does not need to be transparent. Light and ventilation requirements seem to allow solid operable door only with HVAC fresh air makeup and fixed light fixtures. So again, it seems a dark bedroom is possible.

    2009 IRC requirements-


    R310.1 Emergency escape and rescue required. Basements, habitable attics and every sleeping room shall have at least one operable emergency escape and rescue opening. Where basements contain one or more sleeping rooms, emergency egress and rescue openings shall be required in each sleeping room. Where emergency escape and rescue openings are provided they shall have a sill height of not more than 44 inches (1118 mm) above the floor. Where a door opening having a threshold below the adjacent ground elevation serves as an emergency escape and rescue opening and is provided with a bulkhead enclosure, the bulkhead enclosure shall comply with Section R310.3. The net clear opening dimensions required by this section shall be obtained by the normal operation of the emergency escape and rescue opening from the inside. Emergency escape and rescue openings with a finished sill height below the adjacent ground elevation shall be provided with a window well in accordance with Section R310.2. Emergency escape and rescue openings shall open directly into a public way, or to a yard or court that opens to a public way.

    R303.1 Habitable rooms. All habitable rooms shall have an aggregate glazing area of not less than 8 percent of the floor area of such rooms. Natural ventilation shall be through windows, doors, louvers or other approved openings to the outdoor air. Such openings shall be provided with ready access or shall otherwise be readily controllable by the building occupants.

    The minimum openable area to the outdoors shall be 4 percent of the floor area being ventilated.

    1. The glazed areas need not be openable where the opening is not required by Section R310 and an approved mechanical ventilation system capable of producing 0.35 air change per hour in the room is installed or a whole-house mechanical ventilation system is installed capable of supplying outdoor ventilation air of 15 cubic feet per minute (cfm) (78 L/s) per occupant computed on the basis of two occupants for the first bedroom and one occupant for each additional bedroom.

    2. The glazed areas need not be installed in rooms where Exception 1 above is satisfied and artificial light is provided capable of producing an average illumination of 6 footcandles (65 lux) over the area of the room at a height of 30 inches (762 mm) above the floor level.

    For multi family apartments and/or condos (R-2 use group) using the 2009 IBC, it is common to NOT have an emergency escape and rescue window. This happens all the time due to building ht and sprinklers. But I have always indicated windows for the light requirements and typically, operable windows for the natural ventilation requirement.
    But this is an odd situation where the existing conditions will not allow this.

    Where I believed a bedroom required a window, my first thought was to simply review the code, clip out the sections that required the windows and show this to the owner and move on as the project is NOT POSSIBLE.
    BUT I could not find this. All I read indicated a windowless bedroom with out an emergency egress and rescue opening (interior room) IS an option. If the exceptions and artificial light/artificial ventilation requirements are met, its allowed by code.
    Again. prior to this exercise, my initial reaction has always been a bedroom requires a window (but not always an emergency escape and rescue)

    Per 2009 IBC, the emergency escape and rescue window is NOT required for bedrooms at the 4th floor or above. (At this ht, sprinklers will be triggered anyway and thus sim to exception one below and fire truck ladders may not reach anyway) see code section below.

    The emergency escape and rescue window is NOT required if the building is equipped throughout with a sprinkler system. see code section below.

    All I see leads me to the conclusion that if conditions are met, a windowless bedroom is allowed.
    From what I have found, permitting should be no problem. In order to deny the permits, they will need to cite code sections which requires it, And I do not see any.
    Next concern would be FHA/HUD requirements. But I have found none there either. They seem to refer to code compliance. References in FHA/HUD literature I have found mention emergency escape and rescue as required by the building codes.

    Again, seems odd, but I can not find anything prohibiting it.

    Related code sections
    1029.1 General. In addition to the means of egress required by this chapter, provisions shall be made for emergency escape and rescue in Group R and I-1 occupancies. Basements and sleeping rooms below the fourth story above grade plane shall have at least one exterior emergency escape and rescue opening in accordance with this section. Where basements contain one or more sleeping rooms, emergency escape and rescue openings shall be required in each sleeping room, but shall not be required in adjoining areas of the basement. Such openings shall open directly into a public way or to a yard or court that opens to a public way.

    1. In other than Group R-3 occupancies, buildings equipped throughout with an approved automatic sprinkler system in accordance with Section 903.3.1.1 or 903.3.1.2.

    1203.1 General. Buildings shall be provided with natural ventilation in accordance with Section 1203.4, or mechanical ventilation in accordance with the International Mechanical Code.

    1205.1 General. Every space intended for human occupancy shall be provided with natural light by means of exterior glazed openings in accordance with Section 1205.2 or shall be provided with artificial light in accordance with Section 1205.3. Exterior glazed openings shall open directly onto a public way or onto a yard or court in accordance with Section 1206.

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