Lowered Thresholds for Commissioning
Under the previous Michigan rules, only projects above 50,000 sq. ft. were subject to a formal commissioning requirement. The new code lowers that threshold to 10,000 sq. ft. of affected floor area.
This change pulls a large group of “normal” commercial buildings into scope, for example offices, schools, healthcare facilities and mixed-use projects that would previously have fallen below the line.
These projects must now plan for commissioning as part of the energy-code route, rather than relying only on basic startup and punch lists.
Verification & Testing (V+T) for Buildings Under 10,000 sq. ft.
Buildings under 10,000 sq. ft. are not required to follow the full commissioning process, but they still have to show that key systems work in operation through a separate Verification & Testing track.
The focus is narrower and follows the systems with the largest impact on energy use. In practice, that usually means HVAC controls, service-hot-water controls and lighting controls.
Design intent is documented for the installed systems, and targeted functional tests are developed to show that they follow the specified sequences. On more complex small projects, owners sometimes go beyond the minimum and request integrated IST testing to demonstrate that multiple systems interact correctly under realistic scenarios.
Commissioning Requirements for Buildings Over 10,000 sq. ft.
For buildings at or above 10,000 sq. ft., the code expects a structured commissioning process that starts in design and runs through completion.
A commissioning plan is required - and it should state which systems are included, which tests will be carried out, and how results will be documented and handed over.
Michigan leans on ASHRAE 90.1 and ASHRAE 202, so the commissioning provider is expected to act independently from both the design team and installing contractors. Typical scope covers HVAC and service hot water together with the control strategies that drive energy use.
By the time the project reaches occupancy, the provider should be able to prove that systems match the design intent and that FPT has been completed using agreed procedures and acceptance criteria.
Increased Focus on Functional Performance Testing (FPT)
Functional Performance Testing sits at the center of Michigan’s new approach. In plain terms, FPT is about proving that equipment and controls behave as intended when the building runs. Definitions borrowed from IECC 2021 and ASHRAE 202 describe FPT as a structured, repeatable procedure.
It must define what is tested, which conditions are simulated, what results are expected and how outcomes are recorded.
Michigan’s adoption of these standards means FPT is now required for code-regulated systems rather than left to the discretion of individual teams.
The code also expects FPT providers to be identified in the construction documents and to be separate from the people who designed or installed the systems being tested. That independence is central to the credibility of the tests.
Controls, Energy Monitoring, and Documentation
The new energy code also tightens the rules around controls and the evidence that they were tested. HVAC controls, service hot-water controls and lighting controls all have explicit functional-testing requirements in the underlying standards. Michigan’s implementation brings those requirements into everyday practice.
Whole-building energy monitoring appears more often in design discussions, and the code expects metering and related control functions to be verified as part of the commissioning or V+T scope. That helps owners confirm that the building can actually be operated in line with its energy targets.
On the documentation side, Michigan follows the IECC structure with preliminary and final commissioning reports. These must describe what was tested, what passed, what needs to be corrected and which tests are deferred due to season or conditions. Operation and maintenance information and training records are part of the same story.
What This Means for Owners, Designers, and Contractors
For Michigan project teams, commissioning and FPT now sit alongside structural design and fire protection as code topics that require a clear plan from the outset. This means:
- Owners should decide early how commissioning and V+T will be handled and make it an explicit part of the project scope.
- Designers should reserve space in the design and in the schedule for tests, define sequences of operation in advance, and ensure there is practical access for verification.
- Contractors should coordinate with the commissioning provider, confirm that systems are ready for testing, and address findings without long delays.
The positive side is that the code now follows recognised best practice. Projects that adopt a structured commissioning approach typically face fewer last-minute issues and achieve a more controlled handover to operations.
How CxPlanner Helps Navigate Michigan’s Requirements
CxPlanner is a commissioning software built to turn requirements like Michigan’s energy code into clear scope, test plans and traceable records. Instead of scattered spreadsheets and email threads, project teams can keep scope, status and documentation in one place and align commissioning or V+T plans with the chosen compliance path and FPT obligations.
Field data from functional tests is captured once and reused in reports for owners and code officials. The platform also supports IST testing and advanced data center commissioning, so higher-level tests are managed without changing tools mid-project.
This makes it easier to prove that Michigan’s commissioning and FPT requirements are actually met in the finished building.