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Who Must File as a Permit Consultant


A permit consultant is an individual who receives or is promised compensation to provide permit consulting services on a “major project” or a “minor project,” including any employee who receives compensation for time spent on permit consulting services.

“Permit consulting services” means any contact with the Department of Building Inspection, the Entertainment Commission, the Planning Department, or the Department of Public Works to help a permit applicant obtain a permit.  “Permit consulting services” do not include simple requests for information which do not otherwise include attempts to help obtain a permit.

A “major project” is a real estate development project located in the City and County of San Francisco with actual or estimated construction costs exceeding $1,000,000 and which requires a permit issued by the Department of Building Inspection or the Planning Department.   Estimated construction costs are to be calculated in the same manner used to determine building permit fees under the Building Code.

A “minor project” is a project located in the City and County of San Francisco which requires a permit issued by the Entertainment Commission.

The following individuals are not permit consultants and thus are not required to register or report:

  • a licensed architect or engineer of record for construction activity allowed or contemplated by the permit, or an employee of that architect or engineer;
  • a contractor who will be responsible for all construction activity associated with the requested permit, or an employee of that contractor; or
  • an employee or agent of an organization with tax exempt status under 26 United States Code Section 501(c)(3) communicating on behalf of that organization regarding the development of a project for that organization. 

Permit Consultants Who are also Lobbyists

A permit consultant who also qualifies as a lobbyist may elect to file only lobbyist reports (and not the quarterly SFEC Form 3410B) so long as he or she discloses on those reports all information required to be reported on SFEC Form 3410B.  You must make this election by checking the appropriate box on page 1 of the registration form (SFEC Form 3410A).  Please note that a permit consultant/lobbyist making this election will be required to disclose more extensive information on the lobbyist reports, including the date of each contact made. Please also note that a permit consultant/lobbyist must continue to file in this manner through the end of the calendar year, or until you terminate as both a lobbyist and a permit consultant, whichever is earlier.


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