I dont believe it is required by code to have a 3 way switch in a hallway, correct? Brand new construction, and the upstairs hallway lights only have one switch at the stairs.
This would require turning the light off, and then walking in the dark to the bedrooms.
Other than being a nuisance, and not common building practice, the builder wouldnt be required to do anything about it, correct?
3-way switches would be a design issue not a code issue. There needs to be at least one switch for the hallway.
210.70(A)(2) Additional Locations.
Additional lighting outlets shall be installed in accordance with the following:
(1) At least one lighting outlet controlled by a listed wall-mounted control device shall be installed in hallways, stairways, attached garages, and detached garages with electric power.
I would write it up as a potential safety issue regardless of code.
The buyer of the house could request one be installed, but who pays for it to be installed would be between the buyer and the builder.
Another option that I recommend that would be an easy fix, would be to install smart bulbs. 
Here too…
I know HI’s write up potential safety issues but if this truly were an issue regarding safety don’t you think that 3-way switches would be required by the NEC? Are new homes built to minimum code standards unsafe?
From a quick Google search and on HD website.
Residential Electrical Code Requirements - The Home Depot
Hallways more than 10 feet long must have outlets for general use. Three-way switches are required at each end to turn a ceiling light on and off.
Maybe they should change it to be 5 feet long. 
I thought I remembered something about 3-way switches being required but I deferred to Rob’s expertise.
I looked in the 2023 NEC code changes and could not find that requirement for a lighting outlet.
I’ve seen homes where the builder placed the hallway switch at the ‘middle’ of the hallway to circumvent the “each end” rule!
Sometimes, when on a second story, their excuse was “that is where the staircase is”, regardless that there was a 10+ ft hallway in ‘both’ directions (centered staircase).
Am I correct this scenario would also require the addition of a 4-way switch, (along with the two 3-way switches), to operate the hallway lighting from both ends and center (top of stairs)? I have seen homes with seperate lighting/switching for each side-hallway,
Three and four-way switching – Basic Lighting for Electricians: Level 1.
Is this the switch? One could fall down the stairs while stumbling around to find the switch. Crazy.
That would be my concern, (walking from the bedrooms to the staircase), as opposed to what the OP mentioned.
The 10 foot rule is incorrectly quoted constantly. IRC E3901.10 says “Hallways of 10 feet or more in length shall have at least one receptacle outlet.”
IRC E3903.3 says that “at least one wall-switch-controlled lighting outlet shall be installed in hallways,” etc
I don’t know about the NEC but apparently most builders in my area feel that is a safety issue. 99% of homes in my area built in the last 30 years have three-way switches at bottom and top of stairway and in hallways.
Code is a minimum standard and builders can go beyond code. However, IMO, home inspectors should tread carefully when reporting that something should be done that is beyond code. If your local AHJs want to see something done that is beyond code, then you should inspect with that in mind. When you start saying that something should or must be done that is beyond code, I think you are over-stepping your role as a home inspector. If you feel that you should make recommendations that are beyond code, you should make it clear that you are stating an opinion and not a code requirement.
Yes, that is the only one for the hallway
Or a little $3 plug-in night light in one of the receptacles.
That’s typical here as well.
Required to have one at each end of stairs, and then each end of hallway for convenience
Agreed, here was my comment:
"The upstairs hallway only has one switch at the top of the stairs.
Typically, there would also be a switch at the other end of the hallway to turn off lights in the path of travel.
This one would require turning the light off, and then continuing to the bedroom in the dark. Recommend builder verify that an extra switch was not required on the electrical plans. Although it may not be a code issue, it is common practice and convenience to install 3-way switches"
