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Certificate of Occupancy (Change of Use/Occupancy) in Unincorporated Doña Ana County, New Mexico

Required under the adopted 2021 International Building Code (IBC) § 111, which Doña Ana County's own local amendments (DAC Code § 142-4) do not modify: no building or structure may be used or occupied, and no change in the existing occupancy classification of a building or structure (or portion thereof) may be made, until the Building Official has issued a Certificate of Occupancy (CO). For NEW construction, CO issuance is the final step of the standard Building Permit process — bundled into that permit's own Building Final Inspection (see this file's residential-building-permit entry, inspection order 6) with no separate CO fee or application. For a CHANGE OF USE/OCCUPANCY on an EXISTING building where no new construction/building permit is otherwise triggered, Doña Ana County does not publish a distinct standalone application form, fee schedule, or review-timeline on its Building Services or Community Development web pages — a genuine gap documented here rather than invented.

Reviewed 2026-07-22 · Source

When you need this permit

  • No building or structure may be used or occupied, and no change in the existing occupancy classification of a building or structure (or portion) may be made, until the Building Official issues a Certificate of Occupancy — adopted 2021 IBC § 111, unamended locally per DAC Code § 142-4 (which amends only IBC §§ 3302, 3305, and 107/R106)
  • For new construction, the CO is issued upon successful completion of all required trade finals and the Building Final Inspection under the standard Single Family Dwelling/Building Permit process documented in this file's residential-building-permit entry
  • For a change of use/occupancy classification on an existing building with no associated new construction, apply through the Doña Ana County Community Development Department — Building Services Division; the county does not publish a distinct standalone application, fee, or checklist for this scenario as of 2026-07-22
  • If construction, alteration, or tenant-improvement work is required to accomplish the change of use, that work is separately permitted and fee-assessed as a standard building permit under the Building Permit Fee Schedule's general 'Other Construction' valuation scale (the same treatment this file already documents for the roofing-permit and solar-pv-permit entries)
  • Doña Ana County's subdivision-infrastructure rules (DAC Code § 350-212) can independently withhold a certificate of occupancy for a new building in a subdivision or phase until the required subdivision infrastructure is deemed substantially complete by the County, with a limited exception allowing one model-home/sales-office CO per subdivision phase before that completion

Required documents

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Fee schedule

Certificate of Occupancy Fee (standalone, no associated construction)No CO-specific line item appears in the Building Permit Fee Schedule (PDF) or DAC Code Chapter 179, Article VI (Building Code Fees). For new construction, CO issuance carries no fee beyond the standard building permit fee already assessed; confirm any standalone change-of-use fee directly with Building Services, (575) 647-7350.
Not published
Change of Use Requiring Construction/AlterationDoña Ana County Building Permit Fee Schedule (PDF) — same catch-all valuation table this file's roofing-permit and solar-pv-permit entries use for construction categories with no dedicated fee line item
Assessed under the general 'Other Construction' valuation scale of the Building Permit Fee Schedule (e.g., $45 for $1–$500 up to $790 + $5.00 per additional $1,000 above $100,000)

Review timeline

Plan review
Not published — contact the department

How long did your Certificate of Occupancy (Change of Use/Occupancy) permit actually take in Unincorporated Doña Ana County?

Anonymous — one question, no email. Answers are combined and only shown once at least 5 people have reported.

Inspection process

  1. 1

    Building Final Inspection (new construction)

    For new construction, the CO is issued upon the Building Final Inspection already documented as the final step of this file's residential-building-permit entry (order 6) — no separate CO-specific inspection exists in that scenario.

  2. 2

    As-Built / Occupancy Classification Verification (change of use on existing building)

    For a change of use on an existing building with no new construction, no distinct published inspection checklist was found; a site visit by the Building Official to confirm the building meets the applicable code requirements for the new occupancy classification is standard IBC § 111 practice, but Doña Ana County does not itemize this on any published document — confirm the process with Building Services, (575) 647-7350.

See the full Unincorporated Doña Ana County inspection guide — scheduling & re-inspection fees →

Tips

  • Most homeowners and contractors never see a distinct 'Certificate of Occupancy' step because it's bundled into the standard Building Permit's final inspection (already documented in this file's residential-building-permit entry) — this entry exists to document the genuinely separate legal requirement (2021 IBC § 111) for changing an existing building's occupancy classification without new construction, which is far less well-documented on the county's own site.
  • A conditional building permit for a new subdivision can be capped by the county at 10% of that subdivision's total lots, and no CO can be issued for buildings on that permit until the required subdivision infrastructure is deemed substantially complete — except for one model-home/sales-office CO per subdivision phase (DAC Code § 350-212).
  • No standalone fee, application form, or review-timeline for a stand-alone change-of-use/CO request (i.e., no new construction involved) is published anywhere on the county's website as of 2026-07-22 — call Building Services, (575) 647-7350, before assuming a self-serve process exists.

Frequently asked questions

Yes. Adopted 2021 IBC § 111 prohibits any change in a building's existing occupancy classification until the Building Official issues a Certificate of Occupancy. Doña Ana County has not locally amended this section (DAC Code § 142-4 amends only unrelated sections), but the county also does not publish a standalone application, fee, or timeline for this specific scenario — contact Building Services, (575) 647-7350.

Not for new construction — CO issuance is bundled into the standard building permit's final inspection with no extra charge. For a standalone change-of-use request with no associated construction, no fee is published; if construction/alteration work is needed, it's billed under the Building Permit Fee Schedule's general 'Other Construction' valuation scale.

Unincorporated Doña Ana County does not publish a plan-review timeline for this permit. Contact Doña Ana County Community Development Department — Building Services Division at (575) 647-7350; Fax (575) 525-6131; TDD (575) 525-5951 for current turnaround.

You'll need: Certificate of Occupancy Application / Change of Use Request. See the required-documents checklist on this page for details on each.

Unincorporated Doña Ana County requires 2 inspection(s) for a certificate of occupancy (change of use/occupancy) permit, in order: Building Final Inspection (new construction), As-Built / Occupancy Classification Verification (change of use on existing building). Schedule each through Doña Ana County Community Development Department — Building Services Division ((575) 647-7350; Fax (575) 525-6131; TDD (575) 525-5951).

Apply through Doña Ana County Community Development Department — Building Services Division at 845 N. Motel Blvd., Room 150, Las Cruces, NM 88007. Phone: (575) 647-7350; Fax (575) 525-6131; TDD (575) 525-5951, email: buildingservices@donaana.gov. Office hours: County administrative offices open at 8:00 AM (confirmed via the county's own delayed-opening notice stating a 2-hour delay resumes 'normal operations' at 10 a.m., i.e. normal opening is 8:00 AM); the Building Services Division's own site does not publish a distinct closing time or Building-Services-specific hours separate from general county office hours, and no further closing-time citation could be independently confirmed after checking the department's own pages, the county homepage, and the general department directory.. Official information: https://www.donaana.gov/departments/community_services/building_services/permit_requirements.php.

Unincorporated Doña Ana County, New Mexico has adopted: New Mexico is a statewide-minimum-code state under the Construction Industries Licensing Act (NMSA 1978 § 60-13-44(E)): 'All political subdivisions of the state are subject to the provisions of codes adopted and approved under the Construction Industries Licensing Act. Such codes constitute a minimum requirement for the codes of political subdivisions.' A county or municipality may become its own code-enforcement authority (operate independently of the state Construction Industries Division field office model) if it employs a certified building official and has adopted at least the current state minimum code standards (NMSA 1978 § 60-13-41(D)-(F)). GOVERNANCE MODEL CONFIRMED: unlike some New Mexico counties that route permits through the state CID field office, Doña Ana County SELF-ADMINISTERS for all trades — Building, Electrical, Plumbing, and Mechanical alike — through its own Community Development Department / Building Services Division, headed by Sean Vick, the Doña Ana County Certified Building Official/Assistant Director (per the department's own 'Welcome to Building Services' page). The division also employs its own Certified Building Inspector (Jesse Gomez), Certified Electrical Inspectors (Riley Roman, Joel Candelaria), and Certified Plumbing/Mechanical Inspectors (Candido Jasso and David Murillo) — confirming direct county-level review and inspection for every trade, not CID field-office enforcement.; 2021 International Building Code (IBC) — per the Doña Ana County Building Services 'Building Codes' page (donaana.gov); 2021 International Residential Code (IRC) — per the Doña Ana County Building Services 'Building Codes' page; 2021 International Energy Conservation Code (IECC) — per the Doña Ana County Building Services 'Building Codes' page; the county's own Single Family Dwelling Permit Application requires a signed '2021 RESCheck' Energy Certificate, confirming the 2021 IECC edition is the one actually enforced in practice; 2021 Uniform Mechanical Code (IAPMO) — per the Doña Ana County Building Services 'Building Codes' page; 2021 Uniform Plumbing Code (IAPMO) — per the Doña Ana County Building Services 'Building Codes' page; 2021 International Existing Building Code (IEBC) — per the Doña Ana County Building Services 'Building Codes' page; 2017 ICC/ANSI A117.1 (Accessible and Usable Buildings and Facilities) — per the Doña Ana County Building Services 'Building Codes' page; 2020 National Electrical Code (NEC) — per the Doña Ana County Building Services 'Building Codes' page (this matches the current 14.10.4 NMAC statewide adoption also enforced in the City of Las Cruces; NOTE: the county's own Reroof & Reroof/Overlay Permit Requirements handout still lists an older code slate — '2015 IRC; 2015 NMRBC; 2009 Energy Conservation Code; 2015 Uniform Plumbing Code; 2015 New Mexico Plumbing Code; 2012 Swimming Pool, Spa, Hot Tub Code; 2015 Uniform Mechanical Code; 2015 New Mexico Mechanical Code; 2012 New Mexico Solar Energy Code; 2017 NEC; 2017 New Mexico Electrical Code' — this appears to be a stale, unrevised handout PDF; the county's live, currently-published Building Codes page (2021 IBC/IRC/IECC/UMC/UPC family, 2020 NEC) is treated as the authoritative current adoption for this entry); 2021 International Fire Code (IFC) — per the Doña Ana County Building Services 'Building Codes' page; 2012 Uniform Swimming Pool, Spa and Hot Tub Code — per the Doña Ana County Building Services 'Building Codes' page; Doña Ana County makes clear it cannot host these copyrighted code texts online and directs the public to review physical copies in person at the Building Services Dept., 845 N. Motel Blvd., Las Cruces, NM, or to consult the New Mexico Regulation and Licensing Department (RLD) Construction Industries Division's own current-adoption page for the statewide baseline (rld.nm.gov/construction-industries/rules-laws-and-building-codes).. Local amendments apply — see the Unincorporated Doña Ana County overview page for the full list.

Sources & verification

Key facts verified against official sources. Last reviewed 2026-07-22.

Fees, timelines, and adopted codes are researched from each jurisdiction's published records — see how we verify. Requirements change and vary by project, so always confirm the current details with the Unincorporated Doña Ana County building department before you submit. PermitBase is an independent reference and is not affiliated with any government agency.