Major Alteration & Replacement Works: What Lift Owners Need to Know Under BC(FI) Regulations 2025

Planning lift modernisation for your building? Under the BC(FI) Regulations 2025, the scope of work determines everything—your timeline, budget, and regulatory pathway.
The new regulations distinguish between two types of major works: Category A and Category B. Category A works require comprehensive plan submission and BCA approval before installation begins, while Category B works follow a streamlined notification process. Understanding which category applies to your project is critical for planning correctly.
This guide explains what qualifies as Category A versus Category B works, provides practical classification guidance, and outlines the requirements for successful project execution.
If you're looking for information on other BC(FI) Regulations topics, click on the following links:
- BCA Fixed Installations Regulations 2025: What Singapore Lift Owners Need to Know
- FI Plan Submission Requirements: Complete Guide
- Qualified Person (QP) Roles & Fixed Installation Inspectors Explained
- MCST Guide: BC(FI) Regulations 2025 & Condominium Preparation
- BCA Reportable Matters Regulations 2025: Incident Reporting
Understanding Major Alteration or Replacement Works
Major alteration or replacement works go beyond routine maintenance. These are significant projects that modify or replace key lift components, affecting how the system operates. The BC(FI) Regulations define these works in the First Schedule and categorise them into two distinct types.
The key distinction from routine maintenance lies in project scope. Regular maintenance involves monthly inspections, adjustments, and minor repairs that keep your lift running safely. Major works involve replacing entire systems, upgrading safety components, or making structural modifications that fundamentally change the lift's design or capacity.
Why BCA Created Two Categories
BCA employs a risk-based approach to major work regulation. Not all significant projects pose the same level of complexity or safety impact. Some projects affect the fundamental design of the lift installation and require comprehensive technical review before work begins. Others involve substantial component replacements but don't significantly alter the overall system design.
Category A works require plan submission because they affect critical safety elements like structural loads, refuge spaces, or safety system integration. BCA needs to verify compliance at the design stage to prevent safety issues from emerging after installation.
Category B works still require professional oversight during installation, but the streamlined process acknowledges that these projects have less design impact. They bypass formal plan submission while maintaining quality through mandatory QP supervision.
The PTO Impact
Regardless of category, all major alteration and replacement works share one critical commonality: your existing Permit to Operate automatically ceases upon commencing work. This isn't simply a renewal situation—you must apply for a Lift Recommissioning PTO application before your lift can legally operate again.
This requirement affects your project timeline significantly. Even after physical work is complete, you'll need 2-3 weeks for the PTO application process. Both categories require Supervisor QP certification as part of this PTO application, meaning professional oversight continues through to final certification.
Category A Works: Plan Submission Required
Category A works are explicitly listed in the First Schedule of the BC(FI) Regulations. These projects significantly affect your lift's design and require BCA approval before installation can begin. The regulatory process adds 6-12 weeks to your project timeline but ensures compliance from the design stage.
What Qualifies as Category A?
For lift modernisation projects, five specific types of work trigger Category A classification. Understanding these categories helps you plan your project correctly from the outset.
Increasing the car's available area means physically enlarging the lift car to accommodate more passengers or larger loads. This might involve expanding from 1,000 kg to 1,600 kg capacity, or modifying car dimensions to meet wheelchair accessibility requirements. These changes affect structural calculations, hoistway dimensions, and safety clearances throughout the entire installation.
Adding car or landing entrances involves creating new doorways where none existed before. Common examples include converting a single-door car to a through-car configuration, or adding side entrances to optimise building traffic flow. These modifications affect hoistway design, door safety systems, and emergency access procedures.
Changing car mass by 5% or more can happen more easily than many building owners expect. This refers to the lift car structure itself—not passenger capacity. Premium interior upgrades using marble flooring or glass panels often trigger this threshold. Mass changes affect rope specifications, counterweight calculations, and safety gear capacity, requiring comprehensive verification.
Modifying car bottom or overhead clearances typically involves structural work to the building itself. You might be deepening the lift pit to increase bottom clearance, or raising the machine room to adjust headroom. These refuge spaces are critical safety requirements under Singapore Standard SS550:2020, and any modifications require careful design review.
Changing electrical, electronic, or programmable electronic safety devices represents the most common trigger for Category A classification in comprehensive modernisation projects. Most buildings with lifts older than 15-20 years need safety system upgrades to meet current standards. Installing ACOP (Ascending Car Overspeed Protection) or UCMP (Unintended Car Movement Protection) systems qualifies as Category A work, as does replacing mechanical safety circuits with modern programmable systems.
Why Most Modernisations Are Category A
If you're planning comprehensive lift modernisation for an older building, your project almost certainly qualifies as Category A. Modern safety standards require ACOP and UCMP systems that didn't exist when older lifts were installed. The moment you upgrade these safety devices, you've triggered Category A requirements regardless of what other work you're doing.
This reality affects budget and timeline planning significantly. Even if you're not changing car size or adding entrances, the safety system upgrades alone require plan submission and BCA approval.
The Category A Process
Category A projects follow a defined regulatory pathway. Your appointed Plan Submission QP prepares comprehensive technical drawings and documentation, including all required type testing certificates. This package goes to BCA for review, which takes a minimum 15 working days—though realistic planning should allow 3-4 weeks.
Once BCA approves your plans, they remain valid for 24 months. Installation cannot begin until you receive formal approval. During installation, your Supervisor QP provides physical oversight during all examination, inspection, testing, and commissioning activities. After completion, you apply for a new PTO with QP certification.
The entire process requires both Plan Submission and Supervisor QPs—though the same qualified professional can serve both roles, which helps with continuity and potentially reduces costs.
Category B Works: Streamlined Process
Category B encompasses major works not listed in the First Schedule but still significant enough to require professional oversight. These projects follow a faster regulatory pathway that bypasses plan submission while maintaining quality through mandatory supervision.
Common Category B Examples
Hoisting rope replacement represents one of the most common Category B projects. When you're replacing ropes with the same or similar specifications, this qualifies as Category B work. However, if the rope change affects car mass by 5% or more, the project becomes Category A. Your contractor should verify this threshold before proceeding.
Landing door modifications can be Category B when you're changing door types without adding new entrances. Converting from swing doors to automatic sliding doors at existing openings qualifies as Category B. The key distinction is modifying existing doors versus adding new entrances—the latter triggers Category A requirements.
Safety component replacement within the same specifications includes replacing safety gear, overspeed governors, or buffers with similar capacity components. These are substantial projects but don't fundamentally alter the system design. However, if you're integrating these components into new electronic safety systems, the project becomes Category A.
Car interior refurbishment qualifies as Category B only if the total mass change remains below 5%. Aesthetic improvements like new flooring, wall panels, or lighting upgrades often fall under this category. Always request your contractor to provide mass calculations confirming you're staying below the 5% threshold—crossing it moves your project to Category A.
Category B Still Requires Professional Oversight
Category B doesn't mean "less regulated"—it means "differently regulated." You must notify BCA before work commences, appoint a Supervisor QP for oversight during installation, and apply for a lift recommissioning PTO after completion. The key difference is you bypass the plan submission and approval waiting period, allowing faster project start.
Despite the streamlined process, your Supervisor QP ensures work meets all technical standards and safety requirements. You still need professional certification before BCA will issue your new PTO.
Classifying Your Planned Works
Use this systematic approach to determine which category applies to your project. Correct classification from the outset prevents costly delays and compliance issues.
The Classification Framework
Start by asking: Is this a completely new installation? If yes, you need FI plan submission regardless of category classification. New installations have their own requirements separate from alteration and replacement works.
If you're working on an existing lift, ask: Is this routine maintenance? Simple monthly or quarterly maintenance doesn't trigger major work requirements. You're only concerned with classification if you're doing substantial component replacement or system upgrades.
For major works on existing lifts, check against the five Category A criteria. If ANY of the following apply, your project is Category A:
- Increasing available car area
- Adding car entrance OR adding landing entrance
- Changing car mass by 5% or more
- Modifying car bottom or overhead clearances
- Changing E/E/PE safety devices or PESSRAL components
If none of these criteria apply but you're still doing major work, you have a Category B project. When in doubt, consult with a qualified professional early—misclassification causes significant problems.
Real-World Classification Examples
A comprehensive 20-year-old lift modernisation typically becomes Category A because it includes ACOP and UCMP safety system installation. Even if you're not changing car size or adding doors, the safety system upgrades alone trigger Category A requirements. Budget for 8-12 weeks of additional regulatory process time.
Converting a single-door lift to through-car configuration is clearly Category A because you're adding a car entrance. This project involves significant hoistway modifications and safety system reconfiguration requiring comprehensive design review.
Premium interior upgrades need careful evaluation. If your marble flooring and glass panels increase car mass by 6%, you've triggered Category A requirements. What seems like a straightforward aesthetic improvement becomes a regulated major work requiring full plan submission.
Like-for-like component replacement on the same lift typically qualifies as Category B. You're replacing a major component, but the work doesn't significantly affect overall design. The project moves faster than Category A but still requires QP supervision and new PTO application.
Timeline and Budget Planning
Understanding the timeline and cost implications of each category helps you plan realistically and avoid unpleasant surprises during project execution.
Category A Timeline Impact
Category A projects add significant time to your modernisation schedule. Plan preparation takes 1-2 months depending on project complexity. BCA review requires a minimum 15 working days, but realistic planning should allow 3-4 weeks. If BCA requests clarifications or modifications, add another 2-3 weeks for resubmission and re-review.
Your plans remain valid for 24 months after approval, giving you reasonable flexibility for scheduling installation. However, most building owners want to minimise lift downtime, so installation typically begins shortly after approval.
Installation duration depends on project scope—comprehensive modernisation typically takes 4-6 months. After physical completion, allow 2-3 weeks for new PTO application and approval. Your lift cannot operate during this period, so total downtime extends beyond just the installation phase.
Category A Cost Implications
Expect total project costs to increase by 15-25% compared to the physical work alone. This covers Plan Submission QP professional fees for design review and plan preparation, BCA plan submission fees charged on a per-lift basis, type testing certificate verification for all required components, and Supervisor QP fees for EITC oversight during installation.
For larger projects exceeding 5,000 sqm gross floor area, you'll also need Building Information Modeling (BIM) preparation, adding another cost component. Extended timelines also carry opportunity costs, particularly for commercial buildings where lift downtime affects tenant operations.
Despite these increases, engaging the same qualified professional for both Plan Submission and Supervisor roles can reduce overall professional fees while providing better project continuity.
Category B Advantages
Category B projects move significantly faster because they bypass plan submission and approval. After notifying BCA, installation can begin immediately. This saves 4-6 weeks compared to Category A projects.
You still need Supervisor QP oversight during installation, and you must apply for a lift recommissioning PTO after completion. But the streamlined front-end process means faster project mobilisation and reduced overall timeline.
Cost increases for Category B works typically range from 8-15% above the base physical work, primarily covering Supervisor QP fees and new PTO application costs. This is noticeably less than Category A's 15-25% increase.
Common Planning Mistakes
Avoid these frequent errors that cause project delays and cost overruns.
Starting Work Without Approval
The most serious mistake is beginning Category A installation before receiving BCA plan approval. Some contractors or building owners assume they can start physical work while awaiting regulatory clearance. This violates regulations and triggers stop-work orders.
If BCA identifies unapproved work in progress, you'll face regulatory non-compliance actions, potential fines, and an inability to obtain PTO until you demonstrate full compliance. Prevention is simple: enforce a strict "no work without written approval" policy and confirm approval documentation before contractor mobilisation.
Misclassifying Your Project
Treating Category A works as Category B to avoid plan submission might seem tempting but creates severe problems. When BCA identifies the misclassification—which typically happens during PTO application—you'll face retrospective plan submission requirements, work stoppages until compliance is achieved, and significant project delays with associated cost increases.
The solution is using the classification framework systematically. When uncertain, engage a qualified professional for classification assessment. For genuinely unclear cases, contact BCA directly for clarification before proceeding.
Ignoring PTO Requirements
Never assume your lift can operate immediately after physical work completion. Your existing PTO automatically ceases the moment Category A or Category B works begin. . Operating a lift without valid PTO creates liability exposure and violates building control regulations.
Always plan for 2-3 weeks of PTO application time after work completion. Communicate this timeline clearly to building occupants so expectations remain realistic. Factor this period into tenant communications and contingency planning.
Preparing for Success
Successful major work projects require early planning and professional engagement. These best practices help ensure smooth execution.
Early Professional Engagement
Start discussions with qualified SPE(L&E) professionals 6-12 months before your planned project date. Singapore has a limited pool of these specialists, and demand has increased significantly under the new regulations. Early engagement ensures professional availability when you need it.
Use this early period to conduct preliminary classification assessment, understand realistic timelines and budgets, and begin manufacturer discussions about type testing certificates if needed. For Category A projects, type testing certificate procurement can take several months, making early planning essential.
Realistic Timeline Development
Build regulatory compliance time into your master schedule from the outset. For Category A works, add 8-12 weeks before installation can begin. For Category B works, add 2-3 weeks for notification and initial setup. Both categories require 2-3 weeks post-completion for new PTO application.
Include contingency buffers for potential resubmissions or clarification requests. The first time working under new regulations often reveals unexpected requirements or documentation gaps. A 10-15% timeline buffer helps absorb these learning curve impacts.
Clear Stakeholder Communication
Building occupants need realistic expectations about project duration and lift availability. Explain that regulatory compliance adds time beyond just physical installation. Make it clear that lifts cannot operate without valid PTO, preventing any assumptions about "soft opening" or partial service.
For commercial buildings, work with tenants to plan around the downtime. For residential buildings, explain the MCST approval timeline and regulatory requirements clearly. Transparency prevents complaints and maintains stakeholder confidence throughout the project.
Conclusion
Major alteration and replacement works under the BC(FI) Regulations 2025 fall into two distinct categories with different regulatory pathways. Category A works significantly affect lift design and require comprehensive plan submission, adding 6-12 weeks to your project timeline. Category B works follow a streamlined notification process but still require professional supervision and lift recommissioning PTO application.
The critical universal impact affects both categories: your existing Permit to Operate automatically ceases upon work commencement, requiring lift recommissioning PTO application before resuming lift operation. This reality requires careful planning and clear stakeholder communication.
Success factors include:
- Correct work classification from the project outset
- Early engagement with qualified SPE(L&E) professionals
- Realistic timeline planning with regulatory buffers
- Clear communication with building occupants about requirements
Planning lift modernisation for your building? Hin Chong provides expert guidance throughout the process, from initial assessment through successful PTO approval. Our experienced team works with qualified professionals who understand the regulatory requirements thoroughly.
We help building owners with lift assessment and works classification, realistic timeline and budget development, coordination with qualified SPE(L&E) professionals, and complete project management from design through new PTO approval.
Learn more about our lift modernisation services for expert guidance tailored to your building's needs.
This guide provides practical information based on BC(FI) Regulations 2025 and professional industry experience. For specific technical queries, consult directly with BCA through their official channels.



