Local Law 84 Benchmarking Compliance Services in NYC

Annual ESPM filings, violation removal, and the data foundation for your LL97 compliance.
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Local Law 84
Quick Answer

NYC Local Law 84 (as amended by Local Law 133) requires buildings over 25,000 sq ft to report annual energy and water use through ENERGY STAR Portfolio Manager by May 1 each year. Missing the deadline triggers a $500 violation per quarter, up to $2,000 per year, plus $1,250 for failing to post the resulting energy grade. The fines are small but the data is not. LL84 filings feed your LL97 emissions calculation, your LL33/95 letter grade, and your eligibility for LL97 penalty mitigation. A bad benchmarking filing quietly corrupts a compliance obligation that costs $268 per ton. The Cotocon Group handles LL84 filings, fixes broken data, removes violations, and reconciles benchmarking against LL97 exposure.

2026 Snapshot

LL84 at a Glance (2026)

Question Answer
Who must comply? Buildings over 25,000 gross sq ft; two or more buildings on one tax lot over 100,000 sq ft; two or more condo buildings under one board over 100,000 sq ft; City buildings
What’s reported Whole-building energy use, plus water use if flagged in the CBL
Deadline May 1, 2026 for calendar-year 2025 data no extension this year
Filed via EPA ENERGY STAR Portfolio Manager (ESPM), shared with the City
Late-filing fine $500 per quarter, max $2,000/year (quarterly checkpoints: May 1, Aug 1, Nov 1, Feb 1)
Grade-posting fine $1,250/year under LL33/95
Violation payment DOB NOW: Safety only since December 15, 2025 (eFiling no longer accepted)
Reporting level Per BIN (individual building), not BBL (changed from prior practice)
Exempt Tax Class 1 (most 1-3 family homes), certified garden-style apartments, TIL program buildings
Critical Updates

What Changed for 2026 — Read This Before You File

Three things are different this year, and each one catches owners who are working from last year’s playbook:

Point 1
No Extension in 2026

1. There is no extension in 2026. DOB extended the benchmarking deadline to June 30 in 2025 while owners adapted to the new LL97 reporting portal. That was a one-time accommodation. DOB’s February 2026 service notice states plainly that all reports must be submitted by the statutory deadline and that extensions issued in 2025 do not carry over to filing year 2026. If you assumed you had until June 30 again, you are already late and quarterly penalties began accruing May 1.

Point 2
DOB NOW: Safety Payments

2. Violation payments moved to DOB NOW: Safety. As of December 15, 2025, benchmarking civil penalty payments must go through DOB NOW: Safety. eFiling submissions are no longer accepted, and mail-in and in-person payments are rejected outright. You’ll need an NYC.ID account. Violations are also now searchable in the DOB NOW public portal without logging in search by violation number, address, BBL, or BIN under Compliance Type “Benchmarking LL84.”

Point 3
Per Building (BIN) Level

3. Compliance is measured per building (BIN), not per tax lot (BBL). This is a change from prior practice, and it is the single most common source of filing errors we see. A tax lot with three buildings on it is three benchmarking obligations, not one. Owners who filed at the lot level in past years often have gaps they don’t know about.

Quarterly Penalty Accrual Warning

If you missed May 1, the quarterly clock has already started. The next checkpoints are August 1, 2026 and November 1, 2026 — each one adds $500. Filing now stops the accrual; waiting does not make the existing penalty go away.

Law Overview

What Is Local Law 84 (and Local Law 133)?

Local Law 84, enacted in 2009 as part of the Greener, Greater Buildings Plan, was NYC’s first mandatory building energy law. It requires covered buildings to benchmark annual energy and water consumption using the EPA’s ENERGY STAR Portfolio Manager and share that data with the City.

Local Law 133 of 2016 expanded coverage by lowering the single-building threshold from 50,000 sq ft to 25,000 sq ft, roughly doubling the number of covered properties. The two laws are administered together, which is why you’ll see “LL84/133” used interchangeably with “the NYC Benchmarking Law.”

The purpose is transparency. Benchmarking data is published annually on the City’s building energy map, converted into the letter grades posted in building lobbies under LL33/95, and critically used as the foundation for Local Law 97 emissions calculations.

NYC Local Law 84 Energy Benchmarking Dashboard
Plain Clarification

Benchmarking does not require you to improve anything. LL84 measures; LL97 penalizes. That distinction is why owners underinvest in benchmarking accuracy and why bad LL84 data turns into expensive LL97 problems two years later.

Data Foundation

How LL84 Feeds Local Law 97 — The Part Most Owners Miss

This is the most important section on this page, so we’ll be direct about it. Your LL84 benchmarking submission is not a standalone compliance chore. It is the data layer underneath your entire NYC compliance position:

1. Determines your LL97 emissions baseline

The energy consumption you report under LL84 is converted, using DOB’s emission factors, into the greenhouse gas figure your LL97 compliance is measured against. Overstate your energy use through a meter double-count, a wrong property type, or an unreconciled tenant meter and you manufacture emissions you don’t actually have. At $268 per metric ton over cap, a benchmarking error is not a clerical issue. It is a five- or six-figure exposure.

2. Sets your LL33/95 letter grade

DOB assigns your ENERGY STAR score and corresponding grade from your benchmarking filing. Grades are released October 1 and must be posted near every public entrance by October 31, with a $1,250 annual fine for non-posting. A grade is a public, tenant-facing signal and it comes directly from data most owners never audit.

3. Prerequisite for LL97 penalty mitigation

Buildings pursuing a Good Faith Effort path, a §320.7 hardship adjustment, or any DOB-reviewed mitigation need a clean compliance record across the sustainability laws. A history of benchmarking violations weakens a mitigation position at exactly the moment it matters most.

4. Early-warning system for 2030

Benchmarking gives you a year-over-year energy performance history. Modeled against the 2030–2034 LL97 caps which are dramatically tighter than the current ones that history tells you whether you have a problem coming, and how many years you have to fix it. Buildings that treat LL84 as a data asset find out in 2026. Buildings that treat it as paperwork find out in 2030, when retrofits cost more and double-credit incentives have expired.

The practical upshot: the $2,000 fine is not the reason to take LL84 seriously. The reason is that everything expensive downstream is calculated from it.

Applicability

Who Must Comply — and Who Is Exempt

Covered buildings:

  • A single building exceeding 25,000 gross sq ft
  • Two or more buildings on the same tax lot together exceeding 100,000 gross sq ft
  • Two or more condominium buildings governed by the same board of managers together exceeding 100,000 gross sq ft
  • City-owned buildings meeting the above criteria

Not covered:

  • Real property classified as Tax Class 1 (most one- to three-family homes)
  • Garden-style apartments, when certified by a Registered Design Professional
  • City buildings in the Tenant Interim Lease apartment purchase program
Note the threshold difference from LL97

LL84’s multi-building thresholds are 100,000 sq ft, while LL97’s are 50,000 sq ft. A property portfolio can be covered by one law and not the other. We see this misread constantly owners assume the two laws cover identical building sets. They don’t.

DOB publishes a new Covered Buildings List each February (the 2026 CBL was published in March 2026), and a property’s status can change year to year. Owners are notified in their November property tax bills. Check the current list annually and if your building appears in error due to square footage, that dispute goes to the Department of Finance, not DOB.

NYC Building Portfolio Compliance
Key Calendar

Deadlines and the Quarterly Penalty Clock

Date What happens
February 2026 DOB publishes the 2026 Covered Buildings List
~April 10, 2026 Practical cutoff share your property with the City in ESPM at least 15 business days before the deadline
May 1, 2026 Benchmarking deadline for CY2025 data. No extension this year.
August 1, 2026 Second quarterly checkpoint second $500 penalty if still unfiled
October 1, 2026 LL33/95 energy grades released in DOB NOW
October 31, 2026 Grades must be posted near every public entrance ($1,250 fine)
November 1, 2026 Third quarterly checkpoint third $500 penalty
February 1, 2027 Fourth checkpoint reaches the $2,000 annual maximum
May 1, 2027 Benchmarking deadline for CY2026 data

Penalties stop accruing when a compliant report is accepted not when it is submitted. Violation removal happens only after DOB successfully processes the filing, which is why late submissions with data errors keep costing money even after the owner believes they’ve fixed the problem.

Failure Modes

Where LL84 Filings Actually Go Wrong

DOB audits benchmarking data, and the failure modes are consistent. In our filing work, these are the recurring ones:

Incomplete whole-building data

LL84 requires whole-building consumption base building plus all tenant meters. Multi-tenant office and retail properties routinely file base-building-only data, which understates use and produces an inaccurate ENERGY STAR score. Utilities provide aggregated whole-building data on request, but the request process takes time most owners don’t budget for.

Wrong or stale property type

ESPM property type drives your score and your LL97 emissions cap. Buildings that changed use office converted to residential, retail vacated, a data center added often carry a property type set years ago. DOB explicitly audits property-use data, and “Other” and “Mixed Use” are not valid primary types for single-use buildings.

BBL/BIN entry errors

Both must be entered in exact format in ESPM’s Standard IDs section a 10-digit BBL and 7-digit BIN, with leading zeros. DOB states directly that incorrect BBL/BIN entry may result in a violation. Multi-BIN lots require semicolon-separated entries with no spaces, which is where campus and multi-building properties usually break.

Missing DEP water data

If your building is flagged for water reporting in the CBL, you must first share the property with DEP so water data flows into ESPM. Owners who never completed the DEP sharing step file energy-only reports and get flagged.

Implausible EUI values

DOB expects EUI between roughly 5 and 1,000 kBtu/sq ft. Values outside that band signal a meter or floor-area error and draw scrutiny often revealing a gross floor area that doesn’t reconcile against the sum of property uses.

Data gaps across the calendar year

Every meter needs January 1 through December 31 coverage. A single missing month from a utility account invalidates the submission.

Our Methodology

How Cotocon Handles LL84 Benchmarking: Our 6-Step Process

Cotocon LL84 Engineering Process
1
1. Coverage confirmation

We verify your status on the current CBL, check BBL/BIN accuracy against DOB records, and identify multi-building or campus obligations that split across BINs.

2
2. Whole-building data acquisition

We request aggregated consumption data from Con Edison, National Grid, and other suppliers, coordinate DEP water sharing where required, and assemble a complete calendar year across every meter and fuel type.

3
3. ESPM setup and reconciliation

We build or clean your Portfolio Manager account, correct property types and floor areas, run the EPA error checker, and resolve every alert before submission.

4
4. Filing and confirmation

We share the property with the City, confirm successful transfer, and monitor for BEAM error emails the step where “I filed it” and “it was accepted” diverge.

5
5. Violation removal

For buildings already carrying benchmarking violations, we prepare the compliant filing, handle payment through DOB NOW: Safety, and file challenge requests where the violation was issued in error.

6
6. LL97 reconciliation

We convert your benchmarking data into an emissions figure, compare it against your 2024–2029 and 2030–2034 LL97 caps, and tell you what your filing actually implies for penalty exposure. This is the step nobody else does and it is the entire reason accurate benchmarking matters.

The Cotocon Advantage

Why building owners choose Cotocon

We’ve been filing since the LL84 era began

16+ years in NYC energy compliance, 8,000+ buildings benchmarked.

Benchmarking is not a standalone product for us

Every filing is checked against LL97 exposure, LL33/95 grade impact, and LL87/LL88 obligations one engagement, one compliance calendar.

In-house engineers

Data reconciliation and filings handled by our own team, not subcontracted.

We fix broken histories

Multi-year gaps, wrong property types, BBL/BIN mismatches, and unremoved violations from prior filings.

Get a Free Benchmarking Review Call (212) 889-6566
Common Questions

Frequently Asked Questions

Local Law 84 is NYC’s benchmarking law, enacted in 2009 and expanded by Local Law 133 in 2016. It requires buildings over 25,000 gross sq ft to report annual energy and water consumption through EPA ENERGY STAR Portfolio Manager by May 1 each year. The data is published publicly, converted into LL33/95 letter grades, and used as the foundation for Local Law 97 emissions calculations.

May 1, 2026, for calendar-year 2025 energy and water data. There is no extension this year DOB’s February 2026 service notice confirmed that the 2025 extension to June 30 does not apply to filing year 2026. Quarterly penalty checkpoints follow on August 1, 2026, November 1, 2026, and February 1, 2027.

$500 per quarter, up to a maximum of $2,000 per year, accruing until a compliant report is accepted. A separate $1,250 annual fine applies for failing to post your LL33/95 energy grade near public entrances by October 31.

Since December 15, 2025, benchmarking civil penalty payments must be submitted through DOB NOW: Safety using an NYC.ID account. eFiling, mail-in, and in-person payments are no longer accepted. Payment is by eCheck, credit card, PayPal, or Venmo, with a 2% surcharge on card and wallet payments. Violation removal occurs only after a compliant report is processed paying the fine alone does not clear it.

Yes. Challenge requests are submitted through DOB NOW: Safety with supporting documentation. Common valid grounds include incorrect square footage on the Covered Buildings List, a building erroneously listed, or a documented utility data failure. We prepare and file challenges as part of our violation removal work.

LL84 supplies the energy data that LL97 emissions are calculated from. Your benchmarking filing determines your reported greenhouse gas figure, which is measured against your LL97 cap at $268 per metric ton over the limit. LL84 also feeds your LL33/95 energy grade and supports eligibility for LL97 penalty mitigation. An inaccurate benchmarking filing can create LL97 penalty exposure that doesn’t reflect your building’s actual performance.

No. Both cover single buildings over 25,000 sq ft, but the multi-building thresholds differ: LL84 uses 100,000 sq ft for multiple buildings on a tax lot or under one condo board, while LL97 uses 50,000 sq ft. A property can be covered by one law and not the other. Check both lists separately.

Per building (BIN). Compliance takes place at the individual building level even though the Covered Buildings List identifies properties by tax lot (BBL). This changed from prior practice, and it is a frequent source of filing gaps on multi-building lots.

No unlike LL97, benchmarking doesn’t require certification by a Registered Design Professional. Owners can self-file. In practice, multi-tenant and multi-building properties involve whole-building data aggregation, DEP water coordination, and ESPM error resolution that consume more staff time than the filing appears to warrant, and errors carry downstream LL97 consequences.

You’ll need to create an ESPM account, enter building characteristics and property uses, obtain a full calendar year of whole-building utility data, and enter BBL/BIN identifiers correctly before sharing with the City. First-time filings take longer than owners expect. If prior years were missed, those violations may still be outstanding and should be addressed alongside the current filing.

Only if your property is flagged in the “Required to Report Water Data from DEP” column of the Covered Buildings List. If flagged, you must share the property with DEP so water data flows into ESPM a step that must be completed before your filing will be accepted as complete.

Call (212) 889-6566 or request a free benchmarking review. We’ll confirm your CBL status, check for outstanding violations, and tell you what your current data implies for LL97 typically within one week.
Official Links & Tools

Resources

Official Portals & Tools

Calculate your building’s compliance exposure – The Carbon Shield DOB LL84 Benchmarking Law page & 2026 CBL LL84 Benchmarking Violations – NYC DOB NOW ENERGY STAR Portfolio Manager NYC Sustainability Help Center – Help@NYCsustainability.org, (212) 566-5584

Related Compliance Services

LL97 Compliance Services LL87 Energy Audits & Retro-Commissioning LL88 Lighting Upgrades & Submetering LL95 Lobby Energy Grades Building Energy Benchmarking ENERGY STAR Certification
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