Our Blog

2026 Energy Compliance: What Commercial Building Owners Should Be Planning for Now

A new year brings new opportunities and for commercial building owners, it also brings important energy compliance milestones. While many benchmarking and audit deadlines fall later in the year, January is the smartest time to plan. Early preparation reduces risk, avoids rushed reporting, and often uncovers cost-saving opportunities that directly improve building performance.

As energy performance laws continue expanding across cities and states, understanding what applies to your portfolio in 2026 is essential.

Why Starting Early Matters
for Energy Compliance

The beginning of the year is more than a reset, it's the most strategic window for compliance planning.

Why Start Now?

Owners who plan early often avoid late fees, correction notices, and last-minute consulting costs.

Modern commercial office building at sunrise with digital energy efficiency data overlays showing performance metrics

Energy data visualization helps building owners track performance metrics in real-time.

Key Energy Laws Affecting 2026 Reporting

While requirements vary by jurisdiction, most energy laws fall into two categories:

1. Energy Benchmarking & Transparency

Cities like Los Angeles, New York, Chicago, Denver, and Washington D.C. require annual benchmarking through ENERGY STAR® Portfolio Manager. If you're new to the platform, our team can walk you through the setup process step by step.

Typical requirements include:

2. Energy Audits & Retro-Commissioning

Many jurisdictions require energy audits every 5–10 years, often triggered by:

Audits are not just compliance tools, they often identify operational fixes with strong ROI. Use our commercial building energy audit checklist to prepare for your next assessment.

2026 Energy Benchmarking Deadlines by City

City 2026 Deadline Building Threshold Penalty for Non-Compliance
April 1
20,000 sq ft
$10/sq ft annually
May 1
25,000 sq ft
$268/ton excess CO2
May 1
25,000 sq f
Varies by violation
June 1
20,000 sq ft
Per violation basis
June 1
50,000 sq ft
$100 + $25/day (up to $9,200/yr)
June 1
10,000 sq ft
Per violation basis
June 30
10,000 sq ft
Per violation basis
July 1
20,000 sq ft or 15+ units
$234/ton excess emissions
June 30
50,000 sq ft
$300/day late filing
June 1
25,000 sq ft
$500 first offense

Note: Deadlines and thresholds may change. Always verify with your local jurisdiction's official resources.

Energy engineer reviewing commercial building HVAC systems with tablet during retro-commissioning audit

Professional energy audits identify operational improvements that deliver measurable ROI.

Managing properties in Los Angeles? LA's EBEWE has some of the most aggressive goals following NYC’s Local Laws 84 and 87. Schedule a meeting to find out what your portfolio is required to do and what kind of penalties you may face for non-compliance.

What's New (and Expanding) in 2026

Looking ahead, several trends continue into 2026:

States and municipalities are increasingly using benchmarking data to inform future building performance standards (BPS) making accuracy more important than ever.

The Business Case for Early Action

Energy compliance isn't just about meeting requirements, it supports smarter asset management.

Benefits of Starting Early:

Buildings that consistently benchmark and audit tend to perform better financially over time.

Before and after comparison of commercial building systems upgrade showing improved energy efficiency with green performance indicators

Upgrading building systems delivers measurable efficiency gains and long-term cost savings.

How Insight Energy Consulting Supports You

Insight Energy Consulting helps commercial owners stay ahead of evolving energy laws with:

Whether you manage one building or a national portfolio, early planning simplifies compliance throughout the year. Learn more about our Energy Audit Pathways and BPS services.

Frequently Asked Questions About 2026 Energy Compliance

Energy benchmarking deadlines vary by city. Most fall between April and July 2026. New York City’s deadline is May 1, Los Angeles and Chicago require submissions by June 1, Seattle’s deadline is April 1, and Boston’s BERDO reports are due July 1. Check your local ordinance for exact dates.
Building size thresholds vary by jurisdiction. Washington D.C. has the lowest threshold at 10,000 square feet. Most cities require compliance for buildings 20,000–50,000 square feet or larger. New York City and Denver cover buildings over 25,000 square feet, while Chicago’s threshold is 50,000 square feet.
Penalties range significantly by city. New York City charges $268 per ton of excess CO2 emissions under Local Law 97. Boston’s penalties are $234 per ton. Philadelphia fines $300 per day for late filings. Chicago starts at $100 for the first violation plus $25 per day—potentially reaching $9,200 annually per non-compliant building.

Most jurisdictions require energy audits every 5 to 10 years. Los Angeles requires audits every 5 years under EBEWE. Audit requirements are often triggered by building size, time since the last audit, or changes in ownership. Some cities allow exemptions for buildings that achieve ENERGY STAR certification with a score of 75 or higher.

ENERGY STAR Portfolio Manager is the EPA’s free online tool used by most cities for energy benchmarking compliance. It calculates a 1–100 score comparing your building’s energy performance to similar properties nationwide. A score of 50 is average; a score of 75 or higher qualifies for ENERGY STAR certification.

Benchmarking requires measuring and reporting energy consumption—it’s about transparency. Building Performance Standards (BPS) go further by requiring buildings to meet specific emissions reduction targets, with penalties for non-compliance. Most cities start with benchmarking and later add performance standards.

February is the best time to get ahead of 2026 energy requirements.

A proactive approach now leads to smoother reporting, better performance insights, and fewer surprises later in the year.

Start 2026 informed, and prepared.

Black & White Insight Energy Consulting - logo

Get Help

    Quick Menu

    Black & White Insight Energy Consulting - logo

    Request a Quote


      Insight Energy Consulting

      Request a Quote