What Is Local Law 87?
Local Law 87 of 2009, as amended, requires owners of covered buildings in New York City to conduct energy audits and retro-commissioning studies every 10 years. The findings are compiled into an Energy Efficiency Report (EER), which must be submitted to the NYC Department of Buildings (DOB).
The law exists to close an accountability gap that benchmarking alone can’t fill. Knowing how much energy a building uses (LL84’s job) doesn’t tell you whether that energy is being used efficiently or whether your building’s mechanical systems are operating as designed. LL87 is meant to answer those questions.
It’s worth noting upfront: LL87 requires you to audit and report. It does not require you to implement every recommendation in the audit. The obligation is to investigate and disclose — not necessarily to spend on capital improvements.
Who Has to Comply with Local Law 87?
LL87 applies to larger buildings than most other NYC energy laws. Coverage is based on gross square footage as it appears in Department of Finance (DOF) records:
- Individual buildings greater than 50,000 gross square feet
- A tax lot containing two or more buildings that together exceed 100,000 gross square feet
- Two or more buildings held in condominium form of ownership that together exceed 100,000 gross square feet
This is a higher threshold than Local Law 84, which applies to buildings over 25,000 square feet. If your building is between 25,000 and 50,000 square feet, you are likely subject to LL84 benchmarking but not LL87 auditing — unless your tax lot configuration triggers the 100,000 square foot combined threshold. Not sure whether your building qualifies? This guide explains how covered building thresholds work under NYC’s energy laws.
The DOB publishes a Covered Buildings List (CBL) each year. If your property appears on it, you are legally required to comply. Building owners who believe their property is incorrectly listed can dispute the classification with the NYC Department of Finance.
How the 10-Year Compliance Schedule Works
This is where LL87 differs from every other major NYC energy law. There’s no single annual deadline that applies to all covered buildings. Instead, your compliance year is determined by the last digit of your building’s tax block number.
The rule is simple: when the last digit of the calendar year matches the last digit of your tax block number, that is your compliance year.
For example:
- Tax block ending in 6 → compliance due in 2026
- Tax block ending in 7 → compliance due in 2027
- Tax block ending in 8 → compliance due in 2028
The cycle repeats every 10 years. If your building last filed in 2016, your next submission is due in 2026. If you filed in 2017, your window is 2027.
To find your tax block number, look up your building’s Borough, Block, and Lot (BBL) information through the NYC Department of Finance’s property records.
A note on 2026 deadlines: The standard LL87 submission deadline is December 31 of the compliance year. For buildings due in 2026, the DOB moved the deadline to March 31, 2026. Buildings in the 2026 cohort that have not yet filed should treat their submission as overdue and contact the DOB directly about next steps, as outstanding penalties must be cleared before a late EER will be accepted.
What an Energy Audit Actually Involves
An energy audit under LL87 is a structured, professional review of your building’s energy use. It goes well beyond reviewing utility bills. A qualified auditor — typically a licensed professional engineer or registered architect — examines your building’s mechanical, electrical, and envelope systems to identify where energy is being wasted and what improvements could reduce consumption.
The audit covers systems including:
- HVAC equipment (boilers, chillers, air handling units, ventilation)
- Domestic hot water heating
- Building envelope (insulation, windows, air sealing)
- Lighting systems
- Controls and automation
The result is a report that documents current energy use, identifies inefficiencies, and recommends upgrades with estimated energy savings. These recommendations might range from low-cost operational changes to significant capital projects. Again — you are required to investigate and document, not automatically required to act on every finding.
All LL87 energy audits must be submitted through the U.S. Department of Energy’s Asset Score Audit Template Tool. The format is standardized; reports that don’t use the required template are not accepted.
What Retro-Commissioning Involves
Retro-commissioning (RCx) is a separate but complementary process. While an energy audit identifies opportunities for improvement, retro-commissioning focuses on your existing systems and asks a different question: are they actually working the way they were designed to work?
Over time, building systems drift from their original specifications. Controls get reprogrammed incorrectly, sensors go out of calibration, equipment operates outside intended parameters. Retro-commissioning is the process of finding and correcting those problems — without necessarily replacing any equipment.
A retro-commissioning study typically includes:
- Review of original design documents and current system settings
- Functional testing of HVAC, controls, and related systems
- Identification of operational deficiencies
- Implementation of low-cost corrections (a required part of the process, not optional)
- Documentation of findings in a standardized reporting tool
Unlike the energy audit, retro-commissioning does require you to implement no- or low-cost measures that are identified during the study. Major capital repairs can be deferred, but small operational fixes are expected to be completed as part of the process.
Who Can File an Energy Efficiency Report?
LL87 reports must be filed by a registered design professional — a licensed professional engineer (PE) or registered architect (RA). The EER cannot be self-certified by the building owner or a property manager. Engaging the right professional early matters, both because qualified engineers are in demand during compliance cycles and because the audit process requires meaningful building access and time.
Deferrals and Extensions
Deferrals are available for buildings that can demonstrate compliance with current NYC Energy Conservation Code requirements. Eligible buildings include those less than 10 years old with code-compliant systems, and buildings that have undergone substantial rehabilitation within the prior 10-year compliance period with all base building systems brought to current code. Deferral applications must still be filed by December 31 of the compliance year using DOB Form EER1.
Extensions are available for buildings that need additional time to complete the audit and retro-commissioning work. Extension requests are submitted using DOB Form EER2. Extensions are not automatic — they must be applied for in advance, and the DOB must approve them before the deadline passes.
If you believe your building may qualify for either, beginning that conversation well before your compliance year ends is essential.
What Are the Penalties for Missing Your LL87 Filing?
The penalties for non-compliance are steep and compound over time. Buildings that miss their Energy Efficiency Report deadline face:
- $3,000 for the first year of non-compliance
- $5,000 for each additional year the filing remains outstanding
The DOB will not accept a late EER submission until all accrued penalties have been paid. This is an important detail: you cannot simply file late and move on. The penalties must be cleared first through DOB NOW: Safety, and the process takes time. A building that delays for three or four years is looking at $13,000–$18,000 in penalties before the DOB will even accept the corrective filing.
How LL87 Fits Into the Larger NYC Compliance Picture
Local Law 87 is one of several overlapping energy laws that govern large NYC buildings. Understanding how it relates to the others helps building owners plan rather than react.
Local Law 84 (annual benchmarking) requires you to measure and report energy and water use every year through ENERGY STAR Portfolio Manager. It’s an annual data exercise. LL87 takes that a step further by requiring a professional audit of the systems producing that consumption data.
Local Law 97 (carbon emissions limits) sets hard caps on building greenhouse gas emissions starting in 2024, with escalating penalties for buildings that exceed them. Your LL87 energy audit may identify upgrades — fuel switching, efficiency improvements, controls upgrades — that directly support LL97 compliance. The two laws are complementary, and the audit findings should inform your LL97 strategy.
Local Law 88 (lighting upgrades and submetering) requires covered buildings to upgrade interior lighting and install tenant-level electric submeters. Buildings dealing with LL88 and LL87 in the same period have an opportunity to coordinate the work.
If you’re trying to understand which of these laws apply to your specific building, this guide breaks down the thresholds and requirements side by side. For a broader look at how compliance obligations shape long-term energy planning, see how NYC compliance laws affect heating fuel decisions for building owners.
A Practical Note for Building Owners and Property Managers
The 10-year cycle creates a false sense of distance. Many building owners in the 2026 cohort — blocks ending in 6 — hadn’t thought seriously about LL87 since their last filing in 2016. That gap works against you. Qualified engineers fill up fast during compliance cycles. The audit itself requires full system access, scheduling, testing, and documentation. Trying to start that process in the same year the report is due, let alone in the final months, routinely leads to missed deadlines and penalty exposure.
Buildings in the 2027 cohort have a narrow window to begin planning now and avoid the same situation.
If you’re not sure where your building stands — whether you’re on the Covered Buildings List, what your last filing date was, or how to structure the work — Energo’s compliance team works with building owners and property managers across NYC to navigate exactly these questions. Learn more about our Local Law 87 compliance services.
Local Law 87 Explained: NYC Energy Audits, Retro-Commissioning, and the 10-Year Compliance Cycle
Local Law 87 is one of the more demanding energy compliance requirements facing large NYC building owners — and one of the least understood. Unlike Local Law 84, which requires annual data reporting, LL87 requires a real engineering process: a full energy audit and a retro-commissioning study, completed by qualified professionals, every 10 years.
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