Compliance / NYC Local Law 97

Compliance · New York City only

NYC Local Law 97

Most covered buildings are under their emissions limit today. In 2030 the limit falls, and buildings that heat with gas or oil feel it first.

Local Law 97 gives every New York City building over 25,000 square feet an annual carbon limit, measured from its utility bills, with a penalty of up to $268 for each metric ton over. The first compliance year was 2024, and the Department of Buildings has now published the results. This page sets out who is covered, what changes in 2030, what to do if the building is over, and which decisions have a date on them.

Check my building's 2030 position →Every obligation by address

Checked October 28, 2026. Next report: May 1, 2027, for calendar year 2026. Local Law 97 is a New York City law; it does not reach Westchester, Long Island or New Jersey.

Who is covered

Two articles. Two different paths.

Coverage starts at 25,000 gross square feet for a single building, or 50,000 square feet for two or more buildings on one tax lot or under one condominium board. Which article applies depends on who lives there.

320

Article 320: an annual emissions limit

WhoMarket-rate residential, commercial and institutional buildings that meet the size test.
The limitSet per square foot by the property type reported in ENERGY STAR Portfolio Manager, with one value for 2024 to 2029 and a lower one for 2030 to 2034. A mixed-use building adds up each use.
The filingAn annual emissions report, due May 1, certified by a registered design professional.
The penaltyUp to $268 per metric ton of CO2-equivalent over the limit, each year.

Why a building fine today may not be in 2030 →

321

Article 321: thirteen prescriptive measures

WhoAffordable housing (more than 35% rent-regulated units, HDFC co-ops, or units in a project-based federal program) and houses of worship.
The workThirteen energy conservation measures, ten of them HVAC, controls or mechanical: set points, leaks, heating-system function, radiator controls, pipe and tank insulation, sensors, steam traps, venting, exhaust timers; plus lighting, envelope and radiant barriers.
The filingA one-time report certified by a qualified retro-commissioning agent. The measures were due by December 31, 2024 and the report by May 1, 2025; both dates have passed.
The penalty$10,000 for a late report, and $10,000 for failing to show compliance. The Department of Buildings began issuing these violations in 2026.

The Local Law 87 cycle these buildings still owe →

Buildings that move between articles

A building whose rent-regulated share falls to 35% or less moves to Article 320 on the next January 1. Buildings with 1% to 35% rent-regulated units file their first Article 320 reports for calendar year 2026, due May 1, 2027. Tenant-based vouchers do not count toward the 35%.

The calendar

Three dates. One of them is nine weeks away.

Jan 1, 2027

The beneficial-electrification credit halves, from 0.0013 to 0.00065 tCO2e per kWh, for qualifying electric heating equipment installed and operating on or after this date. Equipment running before it earns the full credit through 2029.

New York City

May 1, 2027

Article 320 emissions report for calendar year 2026. No penalty if filed within 60 days. An extension can be requested from 30 days before to 60 days after May 1 if a design professional was under contract by February 1; in 2026 the extended date was August 29.

New York City

Jan 1, 2030

The 2030 to 2034 limits take effect, and the electricity coefficient halves. The report for calendar year 2030 is due May 1, 2031.

New York City

The Department of Buildings has said that extensions issued by service notice in one year do not carry into the next.

What changes in 2030

The limit falls. Gas and oil do not move.

Both halves of the calculation change on January 1, 2030, and in the same direction. The rule credits electricity at half its current rate because the grid is expected to be cleaner. Natural gas and fuel oil keep the same coefficient in both periods, so a gas- or oil-heated building sees its limit fall by half or more while its counted heating emissions stay where they were. That reading of the rule's tables is ieComfort's analysis; the rule does not describe its own effect.

0.000289 → 0.000145

Electricity, tCO2e per kWh

Halves in 2030 (1 RCNY §103-14).

0.0000531

Natural gas, tCO2e per kBtu

Same value in both periods. Fuel oil does not move either.

0.00758 → 0.00269

Office limit, tCO2e per sf

Multifamily falls from 0.00675 to 0.00335; senior care from 0.01138 to 0.00441.

about $71,600

A year, in a worked example

A 100,000 sf gas-heated office that is under its limit today and changes nothing. ieComfort arithmetic, not a model of any building.

Read the worked example

The article takes a round-number office through both periods, with gas heat and then with heat pumps, and shows why the fuel decision has a 2027 date on it. It also explains why the property type reported in Portfolio Manager matters: there is no skilled-nursing row, and modelling a senior-care campus as a hospital overstates its headroom by more than two times.

The 2030 change falls hardest on gas and oil buildings →

Photo placeholder: boiler room or electrified heating plant. Select this block in Bricks and set the image.

Where enforcement stands

Year one is in. Penalties are real, and small so far.

The Department of Buildings published its year-one results on September 14, 2026, covering calendar year 2024. The figures below are from that report as presented by DOB staff at an Urban Green Council webinar and reported in the trade press. No figures for the 2026 filing cycle (calendar year 2025) had been published as of October 28, 2026.

29,031

Buildings required to report

7% (1,911) had not filed by the deadline; the count was down to about 600 by September 2026.

95%

Of Article 320 filings met their limit

About 9,950 properties under; 470 over, a third of them by less than 10%.

about $270,000

Penalties paid or being paid

By about 15 owners. Five more resolved their notices with offsets.

1,014

Failure-to-file notices (Article 320)

664 went to OATH hearings; 164 emissions notices were also sent. Article 321: 476 notices, and $10,000 violations have begun.

How the over-limit buildings responded

About a third of over-limit properties asked for penalty mitigation. 149 applied for a good-faith penalty break and 102 of those chose a decarbonization plan. The alternative routes were used sparingly: 79 properties used Affordable Housing Reinvestment Fund offsets, 31 used solar, 10 combined heat and power, and 6 claimed the beneficial-electrification credit. Offsets raised $1.7 million, funding two electrification projects so far.

If the building is over

Five routes. Only one touches the gas line.

Reducing use is the only route that changes the heating number. The others reduce or defer the penalty.

Reduce metered use

Counted emissions are metered energy by fuel times a coefficient. Set points, schedules, simultaneous heating and cooling, steam traps and stale overrides all change the number without a capital project, and the Local Law 87 cycle already requires those corrections for buildings over 50,000 square feet.

What controls work does for the number →

Good-faith effort

A penalty-mitigation application showing the building is on a path to its limit, most often a decarbonization plan. Buildings on that plan may not use RECs for 2024 to 2029. Every good-faith route requires Local Law 88 lighting and submetering compliance first.

Renewable energy certificates

RECs offset emissions from grid electricity only, from resources in or delivering into New York City. NYSERDA sold the first Local Law 97-eligible Tier 4 RECs in a 14-day window ending September 2, 2026, at $35.52 each, 50,000 offered, minimum order 1,000; they come from the Champlain Hudson line and count for the 2027 compliance year. From 2030 each REC offsets half as much. There is no percentage cap on RECs in the rule.

Offsets and mediated resolution

Affordable Housing Reinvestment Fund offsets cost $268 per ton and are capped at 10% of the annual limit. Mediated resolution is the process in the rule for settling a notice of deficiency with the Department before a hearing; the Department sets the penalty within the law's "not more than" ceiling.

What the HVAC and controls work does

Operations first. Then the fuel decision.

The 2030 number is a function of three things the owner controls: how efficiently the existing systems run, the fuel the building heats with, and the property type the report uses.

Get the property type right before modelling anything

Limits are set by the type reported in Portfolio Manager. The design professional who certifies the report classifies the building; "Other" and "Mixed Use" are not available.

Correct the operating waste

A retro-commissioning study finds the set points, schedules, overrides and sequences that are using heat the building does not need. A smaller heating load makes the 2030 gap smaller and any replacement smaller too.

Decide the fuel in any replacement made before 2030

Heating or hot-water equipment chosen now runs through the first 2030 to 2034 period. Air-source and VRF heat pumps that exceed a coefficient of performance of 1.5 at 5°F earn the beneficial-electrification credit, claimed inside the annual report, and the credit is twice as large for equipment running before January 1, 2027.

Verify, then report

Functional tests and post-change trends confirm each correction held. Where ongoing monitoring is wanted, it is a separately scoped arrangement, subject to point availability, network approval, cybersecurity, alarm ownership, functional testing and commissioning.

Who prepares and signs

A Local Law 97 exposure review from ieComfort produces the building's 2024 to 2029 and 2030 to 2034 positions under the rule's own coefficients, with the electrification credit shown at both rates and the operating corrections separated from the capital decisions. It is an engineering estimate, not a filing. The annual Article 320 report is prepared and signed by a registered design professional, a New York State licensed engineer or architect, and ieComfort does not certify it. Article 321 prescriptive reports are certified by a qualified retro-commissioning agent.

[RDP partner: name pending, J-2.5] This line will describe the registered design professional ieComfort works with on Article 320 filings.

Who pays for the work

New York programs, with dates on the money.

NYSERDA FlexTech

StudiesShares 50% to 75% of the cost of an energy study, up to the lesser of $500,000 or 20% of annual energy spend.
FitThe exposure review and the retro-commissioning study that precede a capital decision.

Incentives and financing in both states →

NYC

Con Edison commercial programs

BasisPays on the kilowatt-hours and therms the work saves, for new or expanded building automation and for equipment replaced while it still works.
DatesThe 2026 program manual expires December 31, 2026; no 2027 manual had been published as of October 28, 2026. Pre-approval comes before any work starts.

Controls funding by state →

Penalties

Two penalties, plus one for not filing.

$268

Per ton over, per year

The law says "not more than"; the amount is at the Department's discretion.

$0.50 / sf

Per month, failure to file

For up to twelve months after May 1, a maximum of $6.00 per square foot; only if not filed within 60 days.

$10,000

Article 321

For a late report, and again for failing to show compliance.

$500,000

False statements

Civil penalty ceiling, with possible criminal liability.

Pending legislation, including Intro 772 on co-op and condo relief and Int 0159 on a REC cap, had not been enacted as of October 28, 2026 and is not reflected here. A 2030 plan built on the expectation of repeal is a plan with no evidence behind it.

Find out where the building stands in 2030

Send a recent electric and gas bill, the building's Portfolio Manager property types and floor areas, and the equipment list. We read them against the rule's own coefficients and tell you which corrections and which capital decisions move the number, and by how much.

Send the building details →

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

Sources and dates

Where every number on this page comes from.

NYC Administrative Code Article 320 and Article 321; 1 RCNY §103-14 (limits at (c), coefficients at (d)(3), penalties at (g) and (j); amendments effective January 20, 2024 and January 19, 2025); 1 RCNY §103-17; DOB Article 320 Information Guide and Article 321 Filing Guide v1.7 (April 28, 2025); DOB "LL97 GHG Emissions Violations" page.
NYC Department of Buildings, year-one results report (calendar year 2024), September 14, 2026, as presented by DOB at an Urban Green Council webinar and reported by Facilities Dive (September 28, 2026) and Utility Dive (September 29, 2026).
DOB Service Notice, February 27, 2026 (2025 extensions do not apply to 2026); DOB and HPD press release, April 22, 2026.
NYSERDA, Tier 4 REC Voluntary Sales, 2027 vintage: price and quantity announced August 13, 2026; sale window August 19 to September 2, 2026.
Urban Green Council estimates of buildings over the 2024 and 2030 limits.
NYSERDA FlexTech eligibility fact sheet v10 (March 2025); Con Edison Commercial and Industrial Program Manual, Program Year 2026, v1.1.
Last reviewed October 28, 2026. The electrification-credit lines change meaning on January 1, 2027; the Con Edison line rewrites when a 2027 manual is published; pending legislation is not reflected until enacted. Next review January 2, 2027.