Large Building Owners to Submit Benchmarking Data by May 1

Penalties for missing the deadline start at $500 and increase quarterly.



Penalties for missing the deadline start at $500 and increase quarterly.



Local Law 84 (LL 84) requires owners of large buildings to annually measure their energy and water consumption in a process called benchmarking. LL 84 standardizes this process by requiring building owners to enter their annual energy and water use in the U.S. Environmental Protection Agency’s (EPA) online tool, ENERGY STAR Portfolio Manager, and use the tool to submit data to the city. Building owners are subject to a penalty if usage data isn’t submitted by May 1 every year.

The applicable large buildings include private sector buildings that are larger than 25,000 square feet, and two or more private sector buildings on a single lot that are larger than 100,000 square feet. It’s important to note that buildings of this size are also subject to the carbon reduction requirements in Local Law 97, where reports will be due on May 1, 2025.

Violations for Failed Compliance

Once you’ve submitted a satisfactory report by the deadline, there’s no additional responsibility until the following year. If you don’t submit a report by May 1, you may aim for the next quarterly deadline of Aug. 1. Subsequent deadlines are Nov. 1 and Feb. 1 of the following year.

The Department of Buildings (DOB) is authorized to issue violations for any property on the Covered Buildings list that hasn’t provided a benchmarking report by the May 1 deadline. Failure to benchmark will result in a violation and a penalty of $500. Continued failure to benchmark by subsequent deadlines of Aug. 1, Nov. 1, and Feb. 1 will result in additional violations on a quarterly basis and a penalty of $500 per quarter with a maximum of $2,000 per year.

The benchmarking requirements are also tied to Local Law 33 of 2018, which requires applicable large building owners to post DOB-issued Energy Efficiency Rating Labels with letter grades near public entrances. The letter grades rely on the submitted benchmarking data. DOB may issue a notice of violation and failure to display a timely building Energy Efficiency Rating Label will result in a fine of $1,250. The label must be accessed in the DOB NOW Public Portal annually between Oct. 1 and Oct. 31.

Take 4 Compliance Steps

LL 84 gives building owners information about a building’s energy and water consumption compared to similar buildings, and tracks progress year over year to help in energy-efficiency planning. LL 84’s annual benchmarking process consists of four steps:

Step #1: Check the Covered Building List for your property(ies) every year. The city has released its 2024 Covered Buildings List at The Covered Buildings List is sorted by the property’s 10-digit borough, block, and lot number (BBL). You can review your latest property tax bill to find your property’s BBL number. If your property is listed, you’re required to comply. You can also review your property tax bill from the Department of Finance (DOF) for a section titled “One City Built to Last—Compliance Notification.”

If you believe your property should not be on the list, you can send an email to with the following information: the building(s) borough, block, and lot numbers; contact name; contact email address or telephone number; and reason for dispute, with your correct square footage. Your property’s status can change from year to year, so be sure to review the newest Covered Buildings List every year.

If you’re benchmarking a building for the first time this year, you must first enter characteristics of the building (size, completion status, year built, etc.) and primary and secondary building uses into the Energy Star Portfolio Manager (

Step #2: Collect whole building energy data (and water data, if eligible) from utilities. To obtain whole building energy consumption data for benchmarking, you’ll need to obtain tenant consumption data in addition to base building data. If your property isn’t master-metered, or you don’t have whole building energy consumption data, the best way to acquire this information is to request it directly from the utilities.

Energy data. A building owner can obtain aggregated energy data (building’s entire electric and gas consumption for each month of a reporting year) from a private utility. Both Con Edison and National Grid offer automated upload of aggregated consumption data.

Water data. The Department of Environmental Protection (DEP) manages NYC water supply and waste water treatment, and provides all water consumption information to properties that have had an Automatic Meter Reader (AMR) installed for at least the entire previous calendar year; these properties are marked accordingly on the Covered Building List and required to benchmark their water consumption.

If you’ve already connected and shared your property with utilities before, ensure that your property is still shared. National Grid and DEP will upload automatically.

Step #3: Measure and record your energy and water usage in Portfolio Manager. If you’re unfamiliar with using Portfolio Manager, you can study training materials found at

If your building uses fuel oil or other energy that’s not provided by Con Edison or National Grid, within the Portfolio Manager platform, you would create meters under the “Energy” tab as needed, then enter energy use data into Portfolio Manager manually, by uploading a spreadsheet, or by cutting and pasting from a spreadsheet. You’ll need to update your meter with new data every year. If your property was successfully shared with DEP, a water meter will be created and water use data will be uploaded automatically.

Step #4: Submit usage data to the city by May 1 through Portfolio Manager. To complete the benchmarking process, the city’s reporting template must be used in Portfolio Manager to share your data with the city. Use the Portfolio Manager Error Checker on your submitted data by clicking the “Check for Possible Errors” button on the “Summary” tab of each of your properties. You should review and resolve all alerts that are identified. You should also check the basic information and property uses in the “Details” tab for each building of a property to be sure that gross floor area for the building isn’t zero, and floor areas for all property uses add up to the total gross floor area.

Before submitting your report, you should review the benchmarking checklist at to ensure that you’ve completed all the necessary steps. Once you’ve uploaded your data, submitted a response to the template, and received an automatic email confirmation from Portfolio Manager, you’ll have successfully complied with the NYC Benchmarking Law.

For three years following your submission, you should save a copy of the confirmation email from the EPA, energy use information obtained from utility companies, and a copy of the energy use data entered into Portfolio Manager so that they can be made available to the city if necessary.

For help with benchmarking submissions, you can contact the NYC Sustainability Help Center at or (212) 566-5584, Monday through Friday from 9 a.m. to 5 p.m. Trained staff is available to help you through benchmarking steps and resolve problems so that you can meet the May 1 deadline.