Energy Compliance
NYC owner & manager guide • Reviewed October 8, 2026
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Use this guide to organize coverage, deadlines, and follow-up for your buildings. Requirements depend on the property and equipment; confirm applicability and current filing instructions with the responsible agency and qualified professional.
Benchmarking: Local Law 84
Benchmarking reports a covered property’s energy and water use. Accurate identifiers and complete utility data matter as much as clicking submit.
Who should check coverage?
Buildings covered by LL84/LL133. Review the current Covered Buildings List and the law’s coverage rules.
Timing
Annual reporting, ordinarily May 1. Verify that year’s DOB instructions and any official changes.
Your action checklist
1. Confirm BBL/BIN, gross floor area, uses, and utility accounts.
2. Reconcile the full reporting year in ENERGY STAR Portfolio Manager.
3. Submit using the current NYC reporting instructions and resolve errors.
Records to keep
Utility data, property inputs, submission confirmation, and correspondence resolving missing or incorrect data.
Official sources: DOB benchmarking · DOB 2026 sustainability deadlines
Energy grades: Local Law 33
The annual label makes a building’s energy performance visible to visitors and tenants. Benchmarking and label posting are separate steps.
Who should check coverage?
Buildings covered by the energy-grading requirements.
Timing
For 2026, DOB says labels must be posted starting October 1 and no later than October 31. Check the current notice each year.
Your action checklist
1. Download the correct annual label through DOB’s process.
2. Post it conspicuously near each public entrance as required.
3. Keep photographs showing the label, entrance, and posting date, and replace missing or damaged copies.
Records to keep
Annual label PDF, dated posting photographs, and any correspondence about an incorrect label.
Official sources: DOB LL33 energy grading · DOB 2026 sustainability deadlines
Energy audits and retro-commissioning: Local Law 87
An energy audit identifies opportunities to reduce consumption. Retro-commissioning checks that building systems operate as intended.
Who should check coverage?
Generally buildings over 50,000 square feet, with separate combined-property thresholds and exceptions.
Timing
Once every ten years, normally keyed to the tax block’s last digit. The Energy Efficiency Report is due by December 31 in the applicable year.
Your action checklist
1. Confirm the current covered-building record and filing year.
2. Engage the required professionals early enough to complete investigations and corrective measures.
3. Track EER preparation, submission, and any formally granted extension.
Records to keep
Audit, retro-commissioning documentation, equipment findings, EER, and filing confirmation.
Official sources: DOB LL87
Lighting and submetering: Local Law 88
LL88 addresses lighting performance and controls as well as qualifying tenant-space electrical submetering. Replacing bulbs alone may not satisfy it.
Who should check coverage?
Covered buildings and tenant spaces under Articles 310 and 311. Building and space exemptions must be assessed separately.
Timing
The original upgrade milestone has passed. DOB’s 2026 instructions require reports by May 1 for covered buildings that have not demonstrated compliance.
Your action checklist
1. Confirm lighting and submetering obligations with the appropriate professional.
2. Document existing compliant systems, completed upgrades, and legitimate exceptions.
3. Complete the required reporting and tenant electrical-use statements where applicable.
Records to keep
Professional certifications, plans, fixture/control schedules, meter records, statements, and filing confirmation.
Official sources: DOB LL88
Building emissions: Local Law 97
LL97 compliance begins with the correct pathway for each building. Portfolio-level assumptions can hide different obligations at individual buildings.
Who should check coverage?
Generally buildings over 25,000 square feet and certain groups exceeding 50,000 square feet. Exceptions and Article 320/321 pathways matter.
Timing
Article 320 annual reporting has a May 1 statutory baseline. Follow the applicable year’s DOB filing rules and extension process.
Your action checklist
1. Validate BBL/BIN, area, occupancy, and compliance pathway.
2. Engage a registered design professional to prepare the applicable report and review emissions exposure.
3. Submit through the prescribed reporting process and retain acceptance; plan improvements for tighter future limits.
Records to keep
Energy data, calculations, professional certification, approved adjustments, and filing records.
Official sources: DOB LL97
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