Energy benchmarking requirements & deadlines by city and state
A plain-English list of the benchmarking laws we file under most often: who’s covered, when reports are due, and anything extra your building needs.
Good to know: Most laws ask for the previous calendar year’s energy data. Dates below are the usual annual deadlines — cities sometimes grant extensions (Boston moved its 2026 deadline to August 15, for example). Always confirm with your jurisdiction, or ask us and we’ll check for you.
| Jurisdiction | Law | Who’s covered (typical) | Annual deadline | Extras |
|---|---|---|---|---|
| New York City | Local Law 84 | Buildings over 25,000 sq ft | May 1 | Ties into LL97 emissions limits |
| Washington, DC | Clean and Affordable Energy Act + BEPS | Privately owned buildings 10,000 sq ft and up (expanded for 2026) | May 1 | Third-party data verification every 3 years; BEPS performance targets |
| San Francisco | Existing Buildings Energy Performance Ordinance | Non-residential 10,000+ sq ft; residential 50,000+ sq ft | May 1 | Energy audit every 5 years |
| Boston, MA | BERDO 2.0 | Buildings 20,000 sq ft and up | May 15 2026: extended to Aug 15 | Third-party verification; emissions standards |
| Los Angeles | EBEWE | Privately owned buildings 20,000+ sq ft; city-owned 7,500+ sq ft | June 1 | Audit & retro-commissioning every 5 years (due Dec 1) · LA guide → |
| California (statewide) | AB 802 | Commercial & multifamily over 50,000 sq ft | June 1 | Filed with the California Energy Commission |
| Chicago, IL | Energy Benchmarking Ordinance | Commercial, residential & municipal buildings 50,000+ sq ft | June 1 | Data verification on a recurring cycle; Chicago Energy Rating placard |
| Colorado & Denver | Colorado Building Performance Standard; Energize Denver | State: 50,000+ sq ft. Denver: 25,000+ sq ft | June 1 | Performance targets (emissions/EUI) |
| Minnesota | Statewide benchmarking | Buildings 50,000 sq ft and up (2026) | June 1 | Minneapolis has its own program too |
| Austin, TX | Energy Conservation Audit & Disclosure (ECAD) | Commercial buildings 10,000+ sq ft | June 1 | Multifamily has separate audit rules |
| Atlanta, GA | Commercial Buildings Energy Efficiency Ordinance | Buildings 25,000+ sq ft | June 1 | Energy audit every 10 years |
| Philadelphia, PA | Building Energy Benchmarking | Buildings 50,000+ sq ft | June 30 | Building tune-ups for larger buildings |
| St. Louis, MO | Building Energy Awareness Ordinance | Buildings 50,000+ sq ft | May 1 | — |
| Orlando, FL | Building Energy & Water Efficiency Strategy | Larger commercial & multifamily | May 1 | — |
| New Orleans, LA | Energy Benchmarking Ordinance | Buildings 50,000+ sq ft | May 31 | New — first cycle in 2026 |
| Honolulu, HI | Building Energy & Water Efficiency Benchmarking | Larger commercial & multifamily | June 30 | — |
| Lakewood, CO | Energy Benchmarking Ordinance | Buildings 10,000+ sq ft | Dec 31, 2026 | New in 2026 |
What is energy benchmarking?
Benchmarking means tracking a building’s energy (and usually water) use for a full year, entering it into the EPA’s free ENERGY STAR Portfolio Manager tool, and sharing the results with your city or state. Many places publish the results, and some now use them to set performance targets that buildings must meet.
How to know if your building is covered
- Location: laws are set by cities, counties, or states — sometimes more than one applies (for example, California AB 802 and Los Angeles EBEWE).
- Size: most thresholds are based on gross floor area, commonly from 10,000 to 50,000 sq ft.
- Type: some laws cover commercial and multifamily; others only commercial.
- Notice: many cities publish a list of covered buildings or mail a notice — but not receiving one doesn’t exempt you.
Start early — utility data takes time
If your tenants pay their own utilities, you’ll usually need aggregate whole-building data from the utility. Those requests get slower as deadlines approach. We recommend starting in the first quarter of the year.