Compliance guide
Last updated: March 2026
Energy Benchmarking Compliance Guide by City
A comprehensive resource covering every major U.S. energy benchmarking ordinance — what's required, when it's due, and what happens if you don't comply.
Table of Contents
What Are Energy Benchmarking Ordinances?
Energy benchmarking ordinances are local laws that require building owners to measure and report their energy and water consumption annually. The goal is to create transparency about building performance, drive energy efficiency improvements, and reduce greenhouse gas emissions.
Most cities require reporting through ENERGY STAR Portfolio Manager, the EPA's free benchmarking tool. Some cities — like New York and Boston — go further, imposing carbon emission caps with financial penalties for exceeding them.
As of 2026, over 40 U.S. cities and counties have benchmarking requirements, with new ordinances being adopted every year. Below we cover the 10 most significant.
New York City, NY
Ordinance
Local Law 97, LL84, LL133
Year Enacted
2019
Building Threshold
25,000 sq ft
Reporting Deadline
May 1 annually (LL84); ongoing (LL97)
Penalties
$268/metric ton over carbon cap (LL97); $500 quarterly (LL84)
Reporting Portal
ENERGY STAR Portfolio Manager + NYC carbon portal
Key Requirements
- Annual energy & water benchmarking (LL84)
- Carbon emission caps tighten in 2030 (LL97)
- Public energy grade posting A-F (LL133)
- Different limits by occupancy type
Washington, D.C., DC
Ordinance
BEPS (Building Energy Performance Standards)
Year Enacted
2021
Building Threshold
50,000 sq ft (commercial); 25,000 sq ft (multifamily)
Reporting Deadline
Compliance cycle review 2026
Penalties
$7.39/sq ft alternative compliance payments
Reporting Portal
ENERGY STAR Portfolio Manager
Key Requirements
- Meet energy performance targets based on property type
- Offices must achieve ENERGY STAR score of 69+
- Can use renewable energy credits or building improvements to comply
- First compliance cycle 2023; next review 2026
Boston, MA
Ordinance
BERDO 2.0
Year Enacted
2021
Building Threshold
20,000 sq ft
Reporting Deadline
Annual; emissions reduction plans every 5 years
Penalties
Up to $300/ton (can reach $100K+ for large buildings)
Reporting Portal
ENERGY STAR Portfolio Manager
Key Requirements
- Meet greenhouse gas emissions standards starting 2025
- 50% reduction required by 2030
- Net-zero emissions required by 2050
- Must submit emissions reduction plans every 5 years
Seattle, WA
Ordinance
Building Emissions Performance Standard (BEPS)
Year Enacted
2023
Building Threshold
20,000 sq ft
Reporting Deadline
October 1, 2027 (first reporting); targets by October 1, 2031
Penalties
Fines for non-compliance (amounts being finalized)
Reporting Portal
ENERGY STAR Portfolio Manager
Key Requirements
- Meet greenhouse gas emissions intensity targets
- Net-zero by 2045 (commercial) and 2050 (multifamily)
- First major U.S. city to mandate building emissions reductions
New Orleans, LA
NEWOrdinance
Energy Benchmarking Ordinance
Year Enacted
2024
Building Threshold
50,000 sq ft (May 2026); 20,000 sq ft (May 2027)
Reporting Deadline
May 2026 / May 2027
Penalties
$1,000-$3,000 per building
Reporting Portal
ENERGY STAR Portfolio Manager
Key Requirements
- Annual energy benchmarking in ENERGY STAR Portfolio Manager
- Requires 12 months of utility data before filing
- Phased rollout by building size
Detroit, MI
NEWOrdinance
Energy and Water Benchmarking Ordinance
Year Enacted
2023
Building Threshold
25,000 sq ft
Reporting Deadline
June 1, 2026 (for 2025 data)
Penalties
To be determined by enforcement rules
Reporting Portal
ENERGY STAR Portfolio Manager
Key Requirements
- Annual energy & water benchmarking
- First compliance year — many 25k-50k sq ft buildings affected for the first time
- Passed November 2023
New Jersey, NJ
NEWOrdinance
Clean Energy Act (CEA) Energy & Water Benchmarking
Year Enacted
2018
Building Threshold
25,000 sq ft (commercial 4A & residential 4C)
Reporting Deadline
July 1, 2026 (for 2025 data)
Penalties
Compliance deadline published; monetary penalties not listed in current state guidance
Reporting Portal
ENERGY STAR Portfolio Manager (+ BEAM portal)
Key Requirements
- Statewide program administered by the NJ Board of Public Utilities
- Covers commercial (4A) and apartment/residential (4C) buildings over 25,000 sq ft; condos/co-ops excluded
- Annual energy & water benchmarking; first CY2025 submission due July 1, 2026
- MeterID is on the NJ Certified Building Benchmarker List
Chicago, IL
Ordinance
Chicago Energy Benchmarking Ordinance
Year Enacted
2013
Building Threshold
50,000 sq ft
Reporting Deadline
June 1 annually
Penalties
$100-$500 per day
Reporting Portal
ENERGY STAR Portfolio Manager
Key Requirements
- Annual energy benchmarking and reporting
- One of the oldest benchmarking laws in the U.S.
- Covers commercial, institutional, and residential buildings
Denver, CO
Ordinance
Energize Denver Ordinance
Year Enacted
2021
Building Threshold
25,000 sq ft
Reporting Deadline
Annual; performance requirements phase in 2024-2030
Penalties
$2,000-$5,000 per violation
Reporting Portal
ENERGY STAR Portfolio Manager
Key Requirements
- Annual energy benchmarking + performance requirements
- Offices must achieve ENERGY STAR score of 74+
- Performance requirements phase in 2024-2030
Philadelphia, PA
Ordinance
Building Energy Benchmarking Ordinance
Year Enacted
2012
Building Threshold
50,000 sq ft
Reporting Deadline
June 30 annually
Penalties
$300 first 30 days; $100/day thereafter
Reporting Portal
ENERGY STAR Portfolio Manager
Key Requirements
- Annual energy and water benchmarking
- Covers large multifamily (often overlooked market)
Portland, OR
Ordinance
Portland Energy Performance Reporting Ordinance
Year Enacted
2015
Building Threshold
20,000 sq ft
Reporting Deadline
April 1 annually
Penalties
$250 initial + $500 for continued non-compliance
Reporting Portal
ENERGY STAR Portfolio Manager
Key Requirements
- Annual benchmarking + tune-ups every 10 years
- Performance standards coming 2027
Side-by-Side Comparison
| City | Threshold | Deadline | Penalties | Year |
|---|---|---|---|---|
| New York City | 25,000 sq ft | May 1 annually (LL84); ongoing (LL97) | $268/metric ton over carbon cap (LL97); $500 quarterly (LL84) | 2019 |
| Washington, D.C. | 50,000 sq ft (commercial); 25,000 sq ft (multifamily) | Compliance cycle review 2026 | $7.39/sq ft alternative compliance payments | 2021 |
| Boston | 20,000 sq ft | Annual; emissions reduction plans every 5 years | Up to $300/ton (can reach $100K+ for large buildings) | 2021 |
| Seattle | 20,000 sq ft | October 1, 2027 (first reporting); targets by October 1, 2031 | Fines for non-compliance (amounts being finalized) | 2023 |
| New Orleans | 50,000 sq ft (May 2026); 20,000 sq ft (May 2027) | May 2026 / May 2027 | $1,000-$3,000 per building | 2024 |
| Detroit | 25,000 sq ft | June 1, 2026 (for 2025 data) | To be determined by enforcement rules | 2023 |
| New Jersey | 25,000 sq ft (commercial 4A & residential 4C) | July 1, 2026 (for 2025 data) | Compliance deadline published; monetary penalties not listed in current state guidance | 2018 |
| Chicago | 50,000 sq ft | June 1 annually | $100-$500 per day | 2013 |
| Denver | 25,000 sq ft | Annual; performance requirements phase in 2024-2030 | $2,000-$5,000 per violation | 2021 |
| Philadelphia | 50,000 sq ft | June 30 annually | $300 first 30 days; $100/day thereafter | 2012 |
| Portland | 20,000 sq ft | April 1 annually | $250 initial + $500 for continued non-compliance | 2015 |
Frequently Asked Questions
What is energy benchmarking?
Energy benchmarking is the process of measuring a building's energy and water consumption and comparing it to similar buildings using a standard metric, typically through ENERGY STAR Portfolio Manager. Many U.S. cities now require this by law.
Which buildings are required to benchmark?
Requirements vary by city, but generally commercial, institutional, and multifamily buildings above a certain square footage threshold (typically 20,000-50,000 sq ft) must comply.
What is ENERGY STAR Portfolio Manager?
ENERGY STAR Portfolio Manager is a free online tool from the U.S. EPA used to measure and track energy and water consumption, greenhouse gas emissions, and costs. Most city benchmarking ordinances require data to be submitted through this platform.
What data do I need to benchmark my building?
You typically need 12 consecutive months of utility data (electric, gas, water), building square footage, year built, and space type breakdown (e.g., office, retail, parking). MeterID helps gather all of this.
What happens if I don't comply?
Penalties vary by city — from $250 in Portland to $268 per metric ton in New York City. Some cities impose daily fines for continued non-compliance. Beyond fines, non-compliance can affect property valuations and tenant relationships.
Can MeterID handle compliance in multiple cities?
Yes. MeterID manages benchmarking compliance across all major U.S. cities with energy reporting requirements, from a single centralized platform.
How long does the benchmarking process take?
Average turnaround is 2-3 weeks from data receipt to submission. The timeline depends on data readiness — if you already have organized utility records, it can be faster.
Need Help with Compliance?
MeterID handles benchmarking compliance end-to-end — data collection, ENERGY STAR filing, and annual renewals. Book a free consultation or request a quote.