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Compliance · New York City and New Jersey

Energy Benchmarking

Both states make large buildings report their energy use. Only New York City fines the buildings that skip it.

In New York City, buildings over 25,000 square feet benchmark energy, and water where the City meters it automatically, by May 1 each year, and the result becomes the letter grade posted at the door. In New Jersey, commercial and apartment buildings over 25,000 square feet benchmark energy and water by July 1. Both use the same free federal tool, ENERGY STAR Portfolio Manager, and neither requires a licensed professional to file.

Checked October 28, 2026. Next New York City deadline: May 1, 2027, for calendar year 2026. Next New Jersey deadline: July 1, 2027, for calendar year 2026.

Side by side

Same tool, different rules.

The two laws ask for the same kind of report and handle almost everything else differently: who is covered, when it is due, and what happens when a building does not file.

NYC

New York City: Local Law 84

  • CoveredBuildings over 25,000 gross square feet; two or more buildings on one tax lot, or condo buildings under one board, together over 100,000; City buildings. Tax class one is excepted.
  • DueMay 1 each year, for the previous calendar year.
  • ReportsEnergy, and water where the City's automatic meter reading covered the whole year.
  • Who filesThe owner or the owner's representative. No licensed professional has to sign.
  • If missed$500, then $500 for each quarterly deadline still missed (August 1, November 1, February 1), up to $2,000 a year, paid in DOB NOW.
  • New in 2026Compliance is checked building by building rather than by tax lot, and "Other" or "Mixed Use" is no longer accepted as the property type for a single-use building.
NJ

New Jersey: the Clean Energy Act

  • CoveredCommercial buildings and apartment buildings of five or more units (tax classes 4A and 4C) over 25,000 square feet; 11,892 buildings were covered for 2023 data. Condominiums, industrial buildings, schools, houses of worship and most government property are not.
  • DueJuly 1 each year, for the previous calendar year, with a 90-day grace period.
  • ReportsEnergy from every fuel, and water.
  • Who filesThe owner, the operator or an authorized agent. No credential is required.
  • If missedNo fine. The Board of Public Utilities has ordered a public list of buildings that do not respond, but has not published one yet.
  • ProgramsBenchmarking is not a condition for any utility incentive; the Board declined to make it one.
May 1, 2027

Local Law 84 benchmarking for calendar year 2026. May 1, 2027 falls on a Saturday, and the Department of Buildings has not announced a different date.

New York City
Jul 1, 2027

Benchmarking for calendar year 2026, under the Board of Public Utilities' 2022 order, followed by a 90-day grace period.

New Jersey
Oct 2027

New grade labels issue on October 1 and go up within 30 days at every public entrance.

New York City

The data

You do not need every tenant's bills.

The hardest part of benchmarking a building where tenants pay their own utilities used to be collecting their bills. In both states the large utilities now deliver the whole-building total for you.

NYC

New York City

Con Edison and National Grid upload aggregated whole-building energy use into Portfolio Manager when the owner requests it. Con Edison takes the request through its Building Energy Usage Portal and completes the prior year's data by March 1; buildings on the City's covered list receive it monthly. National Grid uploads after the owner shares the property with it in Portfolio Manager. Fuel oil is entered by hand from delivery records, and water comes from the Department of Environmental Protection where the City meters it automatically.
NJ

New Jersey

Utilities with more than 50,000 accounts deliver aggregated whole-building data into Portfolio Manager. Where a building has four or more tenants and none uses more than half of the total, the data comes without tenant consent; otherwise each tenant has to consent. PSE&G customers request it through a Whole Building Request in MySmartEnergy; smaller regulated utilities, including water companies, use the Portfolio Manager spreadsheet template.

Portfolio Manager is staying. ENERGY STAR Portfolio Manager, the tool both states' rules use, is still running and free. Leadership of ENERGY STAR moved from the Environmental Protection Agency to the Department of Energy in 2026, and Portfolio Manager is scheduled to move to the Department of Energy's systems before July 2027. Neither New York City nor New Jersey has announced any change to how filings work.

New York City only: the grade

Your energy grade comes straight from your benchmarking filing.

The letter on the door is the ENERGY STAR score from the Local Law 84 filing, converted to a grade. Miss the filing and the grade is an F, posted at every public entrance. The scale, the posting rules, the 2026 State audit and what moves the score are on their own page: How the grade is set and what to do with it →

  • AScore of 85 or higher
  • B70 to 84
  • C55 to 69
  • DBelow 55
  • FRequired benchmarking not submitted
  • NExempt, or the building type cannot be scored

Posting the label

Issued October 1, posted within 30 days, kept up for a year.

The Department of Buildings issues labels on October 1. Each one goes up near every public entrance within 30 days and stays until the next October 1; the 2026 window ran October 1 to 31. Not posting costs $1,250. Posting steps →

One date, two filings

Benchmarking and the Local Law 97 report are separate.

In New York City, benchmarking (Local Law 84) and the emissions report (Local Law 97) share the May 1 date and are filed separately. Benchmarking is shared with the City through Portfolio Manager. The Local Law 97 report is filed in the Department of Buildings' BEAM portal, which draws its energy data from Portfolio Manager, and it must be certified by a registered design professional. A building that benchmarks carefully has done the groundwork for both.

What to do with the score

A score shows where a building stands. It does not say why.

Both laws require disclosure. New Jersey requires you to disclose how your building performs, not to fix it, and New York City's benchmarking law asks for the filing rather than improvements. A low score in either state usually points at operations before equipment: schedules, set points and sequences that no longer match how the building is used. That is where a controls review starts, and it is cheaper than the capital decision the score might otherwise prompt.

1

Compare like with like

Look at the score against similar buildings and against the building's own prior years. A drop from one year to the next is often more useful than the absolute number.
2

Check the operations first

Overnight and weekend energy use, simultaneous heating and cooling, and outdoor air are the usual places a building wastes energy without anyone noticing.
What a running BAS can hide →

One building, one address

Which benchmarking rules apply, and what the score suggests.

Send the building's address and, if you have it, last year's Portfolio Manager report or the grade on the door. We will tell you which filings apply in its state and what the score suggests about how the building is running.

Until the screening tool is live, this is a short intake form.

Sources and dates

  • NYC Administrative Code Article 309 (§28-309.4, §28-309.5.2, §28-309.12); 1 RCNY §103-06; NYC Department of Buildings Local Law 84 benchmarking page (2026), Energy and Water Data page, and Local Law 33 energy grading page; Local Law 133 of 2016; Local Law 95 of 2019.
  • NYC Department of Buildings Service Notices of February 27, 2026 ("Reminder: Deadlines for Sustainability Laws in 2026") and January 6, 2026 (civil penalties in DOB NOW); "Processing Questions (DOB NOW, ESPM, & BEAM)", April 15, 2026.
  • Con Edison, Aggregated Building Energy Consumption Data and Building Energy Usage Portal; National Grid Portfolio Manager data request; New York State Public Service Commission whole-building data orders (2018).
  • New York State Office of the State Comptroller, "Implementation of Selected Aspects of the Climate Mobilization Act," April 21, 2026.
  • New Jersey Clean Energy Act (P.L. 2018, c.17; N.J.S.A. 48:3-87.10); NJ Board of Public Utilities Order of September 7, 2022 (Docket QO21071023) and Orders of May 22, 2024 and April 23, 2025; Board minutes of December 17, 2025; NJ Clean Energy Program benchmarking pages (2026).
  • U.S. EPA and Department of Energy, Memorandum of Agreement (effective March 3, 2026) and ENERGY STAR Transition Plan (August 28, 2026).
  • Last reviewed October 28, 2026. The 2027 dates are re-checked in early 2027; New Jersey's public list of non-responding buildings is re-checked before each update.