Local Law 84 (LL84) is New York City’s annual energy and water benchmarking requirement for covered buildings. If you own or manage a qualifying property in Brooklyn, Queens, Manhattan, the Bronx, or Staten Island, compliance is not optional — and the deadlines matter.
This guide explains LL84 requirements in 2026, who must file, when it’s due, and how penalties work.
Local Law 84 was enacted to create transparency around building energy and water performance across New York City. It requires owners of certain large buildings to annually measure, track, and report consumption data to the City.
Specifically, LL84 requires owners to:
Benchmark annual energy use
Benchmark water use (where applicable)
Report data through the U.S. EPA’s Portfolio Manager platform
Share the property profile with the City for compliance review
The law is administered by the New York City Department of Buildings (DOB). Reporting is required every year, regardless of whether your building’s performance changes.
LL84 benchmarking and disclosure is law. It does not impose emissions limits — but it directly supports enforcement of newer performance-based regulations.
Compliance is triggered by building size and tax-lot configuration.
Under DOB guidance, “covered buildings” include:
Individual buildings 25,000 gross square feet or larger
Two or more buildings on the same tax lot that together exceed 100,000 gross square feet
Two or more condominium buildings governed by the same board that together exceed 100,000 gross square feet
City-owned buildings meeting the same square footage thresholds
Eligibility is based on Department of Finance records and appears on the City’s Covered Buildings List (CBL).
If your property appears on the CBL, you are legally required to benchmark and report annually.
Being under 25,000 square feet does not automatically exempt you if:
You are part of a larger tax lot exceeding 100,000 square feet, or
You are part of a condo association meeting the combined threshold
Owners frequently overlook tax-lot aggregation rules. Verification against the official CBL is the safest approach.
The annual submission deadline is:
The 2026 filing covers calendar year 2025 energy and water data.
If May 1 is missed, additional quarterly compliance checkpoints apply:
August 1
November 1
February 1 (following year)
These dates are critical because penalties accrue quarterly until compliance is achieved.
Waiting until late April increases risk of processing delays or submission errors.
Failure to file a compliant benchmarking report may result in:
$500 civil penalty per quarter
Up to $2,000 per year in total penalties
Penalties continue each quarter until a compliant submission is accepted.
As of December 15, 2025, benchmarking violation payments must be submitted through DOB NOW: Safety.
Two key points often misunderstood:
Submitting incorrect data does not stop penalties.
Attempting to file without confirmation does not constitute compliance.
Violation removal occurs only after a compliant report is successfully processed.
Filing Local Law 84 is not simply entering utility totals into a form. Compliance requires accurate whole-building benchmarking and verified submission through NYC’s systems.
At minimum, a compliant submission involves:
Setting up the property correctly in ENERGY STAR Portfolio Manager
Entering complete 12-month energy data for all fuel types
Aggregating tenant meters where utilities are not owner-controlled
Verifying gross floor area and use-type allocations
Confirming Borough, Block & Lot (BBL) and BIN identifiers match Department of Finance records
Sharing the property with NYC in time for processing through the City’s BEAM platform
Two areas create the majority of compliance issues:
Whole-building data collection.
Buildings with multiple tenant meters must aggregate total annual consumption. Missing even one account can invalidate submission.
Late sharing and confirmation gaps.
Submitting data inside Portfolio Manager does not complete compliance. The property must be shared with NYC, processed through BEAM, and confirmed. Without confirmation, penalties may continue accruing.
DOB recommends sharing at least 15 business days before the May 1 deadline to allow time for validation and correction.
For single-tenant or centrally metered buildings, internal filing may be manageable. For multi-tenant or portfolio properties, structured oversight reduces the risk of rejected submissions and quarterly penalties.
Local Law 84 compliance is procedural. Accuracy and timing determine whether a filing is accepted — not just whether data was entered.
Across Brooklyn, Queens, Manhattan, the Bronx, and Staten Island, recurring errors include:
Local Law 84 is not complex in theory. It is procedural in execution. Small technical errors can result in violations. Trusting a NYC local law compliance advisor can take the headache out of it.
Local Law 84 does not require a third-party professional.
However, benchmarking requires:
For single-building owners with consolidated utilities, internal filing may be manageable.
For multi-tenant or multi-building portfolios, structured compliance oversight typically reduces administrative burden and risk exposure.
Many NYC owners choose to integrate benchmarking into their broader heating and energy service agreements rather than manage it separately. Energo is currently offering free LL84 benchmarking in your first year with a three-year service agreement.
No. Local Law 97 regulates building carbon emissions and imposes performance limits. LL84 is a benchmarking and disclosure law.
However, LL84 data feeds directly into LL97 compliance strategy.
Yes, if they meet the square footage thresholds individually or collectively.
You may still file. Doing so stops additional quarterly penalties from accruing. However, past penalties may remain payable.
No. LL84 applies only within the five boroughs of New York City.
Beyond avoiding penalties, benchmarking provides operational intelligence.
Annual benchmarking:
For property managers and owners across NYC, early and accurate LL84 compliance reduces risk, avoids administrative scrambling, and positions the building for long-term regulatory alignment.
Waiting until April increases cost exposure and technical risk. Systematic compliance avoids both.
Energo provides full-service Local Law 84 compliance support — from Portfolio Manager setup to data verification, property sharing, and confirmation tracking.
If you’re unsure whether your building is covered or want a compliance review before May 1, our team can guide you through the entire process.
Schedule a Local Law 84 consultation today.
Call: 888-378-9898
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