NYC Building Energy Laws Explained
NYC’s main building energy laws are Local Law 84 (annual energy and water benchmarking), Local Law 33 as amended by Local Law 95 (energy grades and the public label), Local Law 87 (energy audits and retro-commissioning every 10 years), Local Law 88 (lighting upgrades and submetering), and Local Law 97 (emissions caps). Each applies to different building sizes and has its own deadlines. For 2026, the next dates are the LL33 label posting window, which closes October 31, and the LL87 filing deadline for buildings with tax blocks ending in 6, which is December 31.
How to use this guide
If you own one building, read the table, then the section for each law that applies to you. If you manage a portfolio or sit on a board, read the sections on how the laws connect and the 2026 calendar first. Then read the role-based section near the end. Definitions for unfamiliar terms are in the glossary at the bottom.
The laws at a glance
| Law | What it requires | Who it generally
covers |
When it’s due | What happens if you
miss it |
| LL84 | Annual energy and water benchmarking in | Buildings 25,000+ sq ft | Annually, due May 1 | Reporting penalties and enforcement; |
| ENERGY STAR | missing data also | |||
| Portfolio Manager | cascades into LL33 | |||
| and LL97 | ||||
| LL33 (as | Energy grade label, | Covered | Label issued | A building with no |
| amended | posted near each | buildings, graded | October 1; | timely benchmarking |
| by LL95) | public entrance | from | posted by | receives an F grade |
| benchmarking | October 31 | |||
| data | ||||
| LL87 | ASHRAE Level II energy audit and retro- | Buildings over 50,000 sq ft | Every 10 years, set by tax block | Violations and civil penalties; reported as |
| commissioning, filed as | digit; the 2026 | $3,000 in year one | ||
| an Energy Efficiency | cohort is due | and $5,000 each year | ||
| Report | December 31 | after | ||
| LL88 | Lighting upgrades and tenant submetering, | Covered non-residential | Confirm current DOB schedule | Enforcement under the law; confirm |
| with a compliance | buildings (confirm | details before filing | ||
| report | threshold) | |||
| LL97 | Annual emissions | Buildings 25,000+ | Annual report | $268 per metric ton of |
| report against a carbon | sq ft, with specific | due May 1, with | CO2e over the cap, | |
| cap | exemptions | a grace period | every year until | |
| to June 30 | compliance |
How the laws connect
These laws are not independent. They share data, and a mistake in one flows into the others.
Benchmarking is the data foundation. Under LL84, buildings report annual energy and water use. That same consumption data produces the energy grade under LL33 and feeds LL97 emissions calculations. If the benchmarking data is wrong, the grade is wrong, and the emissions estimate is wrong too.
Audits inform emissions planning. LL87 audits and retro-commissioning studies identify the operational and capital measures that reduce energy use. Many of those measures also reduce emissions, so owners often use LL87 findings to plan their LL97 strategy.
The sequence in practice. Clean benchmarking data supports a correct grade and a correct emissions number. Audit findings then point to the work that closes the gap between the building’s emissions and its cap.
The practical lesson: start with the data. A portfolio with clean benchmarking data has a much easier time with everything else.
2026 calendar at a glance
October 1, 2026: LL33 energy grade labels issued.
October 31, 2026: LL33 label posting window closes.
December 31, 2026: LL87 Energy Efficiency Reports due for buildings with tax blocks ending in 6.
May 1, 2027: Annual LL84 benchmarking and LL97 emissions reports due on the standard annual cycle. Confirm the exact date each year.
June 30, 2027: Typical end of the LL97 grace period. Confirm each year.
October 1, 2027: Next LL33 label issued.
Each law in depth
LL84: Benchmarking
What it requires. Covered buildings report annual energy use and water use through ENERGY STAR Portfolio Manager. The data covers whole-building consumption, typically from utility accounts.
Who it covers. Buildings of 25,000 square feet or more, subject to exemptions.
Why it matters beyond reporting. Benchmarking data produces your energy grade under LL33. It also gives you the consumption baseline that LL97 emissions estimates depend on.
A benchmarking error can therefore appear in several places.
Common mistakes.
Missing utility accounts, so the report understates consumption.
Using the wrong property type in ENERGY STAR Portfolio Manager, which changes the benchmark.
Failing to account for a space that changed use during the year.
Assuming last year’s data is still correct after a meter change or a new tenant.
Our LL84 benchmarking mistakes post covers these errors in more detail.
LL33 and LL95: Energy grades and the public label
What it requires. Each covered building receives an energy grade based on its benchmarking data. The grade is issued as a Building Energy Efficiency Rating label, and the label must be posted near each public entrance.
When it’s due. The label is issued October 1 each year. For 2026, the posting window closes October 31.
What happens if you miss it. A building that did not benchmark on time is assigned an F.
Late posting carries penalties. Confirm the current fine amount before advising a client.
Common mistakes.
Posting the label at the main entrance only, when every public entrance must be covered.
Treating the grade as your LL97 status. The grade measures energy use. LL97 measures emissions against a cap.
Not checking the grade against your benchmarking data before posting it.
Read next. The 2026 energy grade explainer and the LL33 posting checklist.
LL87: Energy audits and retro-commissioning
What it requires. Covered buildings complete an ASHRAE Level II energy audit and a retro-commissioning study, then file an Energy Efficiency Report with the Department of Buildings. The audit evaluates how the building uses energy. Retro-commissioning checks that systems operate as designed.
Who it covers. Buildings over 50,000 square feet.
When it’s due. Every 10 years. The filing year is set by the last digit of the tax block number. Buildings with blocks ending in 6 are due December 31, 2026. Our LL87 deadline guide walks through that cohort in detail.
What happens if you miss it. Violations and civil penalties. Published summaries cite $3,000 in the first year after the deadline and $5,000 for each year after that. Confirm the current amounts against the code before relying on them.
Common mistakes.
Not knowing your tax block number. It is part of your BBL, which is borough, block, and lot.
Starting the audit late, when access to systems and utility data becomes the bottleneck.
Treating the audit as a filing exercise and ignoring the recommended measures, which often feed LL97 planning.
Read next. The LL87 energy audit process post.
LL88: Lighting and submetering
What it requires. LL88 requires lighting upgrades to current code standards and, in many non-residential buildings, submetering of tenant spaces. Covered buildings then file a compliance report with the Department of Buildings.
Who it covers. Covered non-residential buildings. Confirm the threshold and any exemptions before advising a client.
When it’s due. Check the current Department of Buildings schedule. Deadlines have changed in the past, so verify before publishing a date.
Why owners should care. Lighting and submetering often produce quick, documented efficiency gains. Submeter data can also help tenant billing and benchmarking accuracy.
LL97: Emissions caps
What it requires. Covered buildings report annual greenhouse gas emissions and must stay within an assigned annual carbon cap. The cap depends on property type and use. Reports are filed annually and certified by a registered design professional.
Who it covers. Buildings 25,000 square feet and larger, with specific exemptions.
When it’s due. Annual reports are due May 1, with a grace period through June 30.
Reporting for 2025 emissions was due May 1, 2026.
What happens if you exceed the cap. The penalty is $268 per metric ton of CO2e over the cap, charged every year the building remains over its limit. The limits tighten for 2030 through 2034.
Worked example (hypothetical, for illustration only):
Tons over cap Annual penalty (× $268)
| 25 | $6,700 |
| 150 | $40,200 |
| 500 | $134,000 |
| 1,000 | $268,000 |
A building that stays 500 tons over its cap for five years pays about $670,000 in total, not counting any change in the cap or rate. That is why the timing of capital work matters as much as the size of the project.
Read next. LL97 penalties explained
Is this you? Where to start by role
Building owner (single building). Confirm your building’s size, block, and BBL. Check which laws apply. Then read the sections on your applicable laws, starting with the next deadline.
Property manager (multiple buildings). Build a portfolio inventory first. You need address, square footage, property type, BBL, and block number for each building. Then map each building to the laws that apply, and build one calendar for the whole portfolio. Read the portfolio section below.
Co-op or condo board. Read the LL97 section and our co-op and condo budget guide.
Boards carry the LL97 exposure and need to understand it before the budget vote.
Developer or owner planning a project. Check how existing laws apply to the building as it will operate, and whether the project’s systems will help or hurt future emissions compliance. Early decisions about heating systems and envelope often determine LL97 exposure for decades.
Starting a portfolio plan
- Build the inventory. For each building: address, BBL, square footage, property type, and year built.
- Confirm coverage. Map each building to LL84, LL33, LL87, LL88, and LL97. Mark any building where coverage is unclear for review.
- Check benchmarking data. Confirm that each covered building’s data is complete and matches its utility bills. Fix errors before anything else.
- Build one calendar. Combine all deadlines in one place, with internal target dates set 30 to 60 days before each legal date.
- Assign owners. Each deadline needs one named person responsible for it.
- Review quarterly. Coverage changes, tenants change, and meters get replaced. Recheck the inventory at least once a quarter.
Glossary
Benchmarking. Measuring and reporting a building’s energy and water use, usually through ENERGY STAR Portfolio Manager.
BBL (borough, block, lot). The three-part identifier for a NYC tax lot. The block number is the middle five digits. The last digit of the block number determines the LL87 cycle year.
CO2e (carbon dioxide equivalent). A unit that expresses all greenhouse gases in terms of their warming effect, so they can be added together. LL97 caps and penalties are measured in metric tons of CO2e.
Energy Efficiency Report (EER). The report filed under LL87 that documents the audit and retro-commissioning results.
EUI (energy use intensity). Energy used per square foot per year. Used in benchmarking to compare buildings of different sizes.
Good Faith Effort. A pathway under LL97 for buildings that have made documented progress toward compliance. Check current rules before relying on it.
Retro-commissioning (RCx). A systematic check that existing systems operate as designed, followed by corrections that restore intended performance.
ASHRAE Level II audit. A detailed energy audit that evaluates building systems, identifies measures, and estimates costs and savings. The standard is set by ASHRAE, the American Society of Heating, Refrigerating and Air-Conditioning Engineers.
FAQ
Q: Which NYC energy laws apply to my building?
A: Coverage depends on square footage, property type, and tax block number. Confirm your building’s details first, then check each law’s threshold. If your building sits near a threshold, confirm with a compliance advisor before assuming it is exempt.
Q: What is the difference between LL84 and LL97?
A: LL84 requires annual energy and water reporting. LL97 uses emissions data to measure buildings against carbon caps and charges penalties for excess emissions. LL84 data feeds into LL97 calculations, but the two laws serve different purposes.
Q: How often is an LL87 audit required?
A: Every 10 years. The filing year is set by the last digit of the tax block number. Blocks ending in 6 are due in 2026.
Q: Which NYC energy law has the next deadline?
A: For 2026, the LL33 label posting window closes October 31. The next filing deadline is LL87 for tax blocks ending in 6, due December 31.
Q: Do the laws apply to condos and co-ops?
A: In most cases, yes. The building owner of record carries the obligation. For condos and co-ops, that is usually the association or corporation. The governing documents determine how costs are shared with owners.
Q: What happens if my benchmarking data is wrong?
A: The energy grade may be wrong, the LL97 emissions estimate may be wrong, and you may need to correct filings. Fix the data as soon as you find the error, and document the correction.
Q: Can I get a building off LL97 entirely?
A: LL97 has specific exemptions, and some buildings may be exempt. Most buildings must comply through a combination of operations, capital work, and other permitted pathways. Check exemption criteria carefully before relying on one.
Q: Where can I check my building’s tax block number?
A: On your property tax bill, or in NYC Department of Finance property records. The block is the middle five digits of your BBL.
