LCQ1, 11 November 2026, reply part (1)
The Buildings Department's rebar photo and video record requirement, explained
Before concrete casting, contractors in Hong Kong will be required to take photographs or videos that record the arrangement of steel reinforcement in the structural elements inspected. Technically competent persons under the project's registered structural engineer verify all of them, and all records go to the Buildings Department (BD) for spot checks. The Secretary for Development announced it in the Legislative Council on 11 November 2026. BD plans to implement it in or before January 2027 and is consulting the industry on the details.
Last updated
What was announced
On 11 November 2026 the Secretary for Development, Ms Bernadette Linn, answered a Legislative Council question on the regulation of building works (LCQ1). The question followed deviations in the installation of steel reinforcement from the approved plans at a residential project at Anderson Road in Kwun Tong and in a house at One Stanley.
The reply says BD doubled its audit checks on the quantity and arrangement of steel reinforcement before and after concreting in May 2025, and is now preparing to tighten regulation of these critical processes further. BD's press release of 21 May 2025 gives the figures. Its own audit inspections of rebar before concreting went from at least 12 per cent to at least 25 per cent of projects a year, and it began covermeter audit checks after concreting on 25 per cent of projects a year.
Before concrete casting, contractors will be required to take photographs or videos to record the arrangements of steel reinforcement in the structural elements inspected. Technically competent persons under the project's registered structural engineer verify them all. All the photo and video records are submitted to BD for spot checks by the department.
After concreting, contractors must engage an accredited laboratory to carry out audit checks on the steel reinforcement. The registered structural engineer reviews the reports, and they are submitted to BD for spot checks.
BD is consulting the industry on the implementation details and plans to implement the enhanced measures in or before January 2027.
The requirement, point by point
What the reply says, and what it leaves for BD to set.
| Question | Answer in the reply | Still open |
|---|---|---|
| What is recorded | The arrangement of steel reinforcement in the structural elements inspected | What each record must show, and at what quality |
| In what form | Photographs or videos | File format and any required labels |
| Who records | The contractor | Which of the contractor's staff |
| Who verifies | Technically competent persons under the project's registered structural engineer, all records | How the verification is evidenced |
| Who receives the records | The Buildings Department, all records, for spot checks | The channel and timing of submission |
| What follows the pour | An accredited laboratory audit-checks the steel reinforcement. The engineer reviews the report and it is submitted to BD | The share of elements audited and the test method |
| From when | In or before January 2027 (planned) | The exact date, and how works already under way are treated |
Source: LCQ1, 11 November 2026, reply part (1). The third column lists matters the reply does not address.
What already applies, and what is new
Inspection records are not new. BD's Code of Practice for Site Supervision 2009 (2024 Edition), paragraph 5.2, says the checklists and inspection records of technically competent persons should be completed contemporaneously and kept on site for inspection by the Building Authority.
Paragraph 10.2 of the Code already mentions photographs. Authorized persons, registered structural engineers, registered geotechnical engineers and the contractor's authorized signatory are required to keep their inspection records at site, such as notes and photo records and the works items inspected, particularly during the critical stages of works.
Three things in the reply go further than the Code. The contractor must take a photo or video record of the rebar before concreting. All of the records are submitted to BD, not kept on site for a visit. And the contractor engages an accredited laboratory to audit-check the rebar after concreting.
Why it matters for the people on site
The reply sets out the Government's reasoning. Its staff cannot be on every site full time to supervise every detail. The system works only if contractors and professionals carry out their own supervisory duties, and know that non-compliance will be uncovered.
The reply says "all" twice. Technically competent persons verify all the records, and all the records go to BD. A record that cannot be matched to its element, date and inspector is hard to verify and hard to defend in a spot check.
The stakes are also rising. Proposed amendments to the Buildings Ordinance are on the agenda of the Legislative Council Panel on Development for 24 November 2026. They would substantially raise the maximum fines for offences such as material deviation from approved plans, speed up disciplinary hearings and tighten registration renewal (reply part (3)).
What to do before January 2027
Decide who records and who verifies
Name the contractor's staff who take the record for each element and the technically competent persons who verify it.
Tie each record to its element
Use the level, grid and element reference on the approved plans, so a record can be found from the drawing.
Keep the date, time and person
Record them at capture, not afterwards. A spot check will ask when and by whom.
Keep the records as a set
All records are submitted, so they need to be complete for each pour and easy to hand over.
Watch for BD's details
The implementation details are under consultation. Check them against your method when they are published.
How Kodifly delivers it
A record for every element
Photos or a 360 walk, placed on the plan by level and grid with date, time and capture ID.
Verification kept with it
The inspection request carries who submitted, who inspected and who approved, and when.
BD rebar record requirement questions
What is the new Buildings Department rebar requirement?
Before concrete casting, contractors will be required to take photographs or videos to record the arrangement of steel reinforcement in the structural elements inspected. Technically competent persons under the project's registered structural engineer verify all of them, and all records are submitted to the Buildings Department for spot checks (LCQ1, 11 November 2026, reply part (1)).
When does the requirement start?
BD plans to implement the enhanced measures in or before January 2027. The reply gives no exact date. BD is consulting the industry on the implementation details.
Who has to take the photographs or videos?
The contractor. The reply says contractors will be required to take them before concrete casting.
Who verifies the records?
Technically competent persons under the project's registered structural engineer. The reply says they verify all of the records, not a sample.
Are the records sent to the Buildings Department?
Yes. All records of photographs or videos are submitted to BD, and the department spot-checks them.
Is there a check after concreting as well?
Yes. After concreting, contractors must engage an accredited laboratory to carry out audit checks on the steel reinforcement. The registered structural engineer reviews the reports, and they are submitted to BD for spot checks.
Why is the requirement being introduced?
The reply links it to the steel reinforcement found not to conform to the approved plans in a house at One Stanley, which had not been reported to the department. BD had already doubled its audit checks on rebar before and after concreting in May 2025.
Are photo records of inspections already required?
Partly. BD's Code of Practice for Site Supervision 2009 (2024 Edition), paragraph 10.2, requires authorized persons, registered structural engineers and the contractor's authorized signatory to keep inspection records at site, such as notes and photo records. The planned measure goes further. The contractor records the rebar before concreting by photo or video, and all records are submitted to BD.
Does the requirement apply to public works?
The reply describes it as a Buildings Department measure. For public works contracts it names two other measures, the Digital Works Supervision System and body-worn video cameras during inspections. The comparison guide sets the three side by side.
Related guides
More rebar records guides
- Public and private worksDoes DWSS apply to private projects in Hong Kong? DWSS and body-worn cameras are for public works. The Buildings Department's rebar record measure is separate.
- What to recordA checklist for the photo or video record of rebar before concreting. What each record should show so it can be verified against the approved plans and spot-checked.
Be ready before the measure starts
Tell us the project and the pour programme. We will show the record on a site like yours, from the first photo to the signed-off set.