Short Answer
An inspection can identify outstanding repairs, but an unresolved defect should not be treated as though the building has already passed the relevant safety process.
For buildings within section 32 bis of the Building Control Act, the owner must arrange inspection by a registered inspector and submit the report to the local official.
The inspection rules distinguish a major inspection every five years from annual inspections in the intervening years. If the inspector finds items that do not meet the applicable criteria or standards, the report must include recommendations for correction.
The regime applies to several prescribed building categories. Hotels with at least 80 rooms are one express example, while smaller hotels or other properties may still qualify because of height, size or use.
The practical sequence is therefore:
identify defect → rectify → recheck evidence → submit / complete inspection process → obtain the regulatory position needed for operation or licensing
Why This Matters
Engineering and legal teams often use “inspection” differently. Engineering may mean the inspector attended site and issued a punch list; management may hear “the building inspection is done.”
A report identifying unresolved fire, electrical, structural or life-safety items is not the same as a clean compliance position. The distinction matters when renewal, reopening, refinancing or a transaction depends on current evidence.
Typical Scenario
A property owner is preparing for an annual or major statutory building inspection.
The inspector identifies several items requiring physical repair. Contractors have been appointed, but the works will not finish before the hotel’s internal target date.
Management asks:
“Can we submit the inspection now and finish the repairs afterwards?”
The answer depends on the findings, local-authority process and the decision relying on the document.
Practical Analysis
01First confirm whether the building is within the statutory inspection regime.
Section 32 bis covers high-rise buildings, extra-large buildings, public-assembly buildings and other categories prescribed by ministerial regulation.
The 2005 regulation expressly includes hotels with 80 rooms or more.
A smaller hotel may still qualify under another category because of height, size or use.
02Distinguish major and annual inspections.
The inspector regulation provides for a major inspection every five years.
Between major inspections, annual inspections are carried out under the annual inspection plan prepared by the inspector.
The compliance calendar should identify the actual cycle rather than use “annual certificate” generically.
03A punch list is part of the process, not the end of it.
Under the inspection regulation, where part of the building or its equipment fails the applicable criteria or standards, the inspector must recommend corrective work.
That identifies the remediation path; it does not prove the defect has been cured.
04Track each defect to closure.
For every item, record:
system → defect → responsible contractor → required correction → completion evidence → inspector recheck if required → authority submission
Fire alarms, emergency lighting, pumps, exits and structural items should not disappear into a generic “engineering in progress” status.
05Separate historical reports from current compliance.
A prior inspection report, old technical specification or building-existence document proves only what that document actually establishes.
It does not prove that current equipment works, later alterations were lawful or the current inspection cycle has been completed.
06Connect the building process to the real business dependency.
Ask why the certificate is needed.
Is it required for a licence renewal, transaction condition, lender requirement, insurer, reopening decision or internal safety programme?
That purpose determines what evidence must be closed before the business treats the issue as resolved.
What We Usually Look At
We review the building category, room count, height and area, latest major inspection, annual inspection plan, current report, defect list, repair evidence, local-authority submission, inspection certificate, building-use documents and any hotel-licensing dependency.
Common Traps
Typical mistakes are saying “inspection complete” when only the site visit is complete, relying on an old report, assuming all hotels use the same inspection regime, treating physical repair and regulatory acceptance as the same milestone and letting legal deadlines run ahead of engineering completion.
Practical Next Step
Use a closure matrix:
inspection requirement → inspection date → failed item → repair → evidence → inspector confirmation → authority filing → certificate / outcome → licence or opening dependency
A property should not move to “green” merely because the repair contractor has been instructed.
Legal Sources
- Building Control Act B.E. 2522 (1979), section 32 bis.
- Ministerial Regulation Prescribing Types of Buildings Required to Have Inspectors B.E. 2548 (2005), including hotels with at least 80 rooms.
- Ministerial Regulation on inspector qualifications, registration and building-inspection criteria B.E. 2548 (2005), particularly clauses 13, 14, 18 and 19 on major inspections, annual inspections and corrective recommendations.
- Department of Public Works and Town & Country Planning / local-authority building-inspection procedures and certificate requirements applicable to the premises.
General legal information only. Please seek advice on your specific facts. Laws and regulatory practice may change.