If you own commercial buildings in more than one city, there is no single "benchmarking day." Every jurisdiction sets its own deadline, its own threshold, and its own penalty, and several of them moved in 2026. This is the verified calendar for the next eighteen months, with every date traced to the government program that sets it. We file these reports, so we keep this current; it is revised every quarter.
What changed in 2026
- Boston BERDO moved its 2026 annual reporting deadline from May 15 to August 15, 2026.
- Seattle waived fines for 2025 benchmarking data while it migrates to a new compliance portal launching July 16, 2026.
- Chicago administratively relaunched its entire benchmarking program on March 5, 2026, with a new platform and support team. Same June 1 date, different back end.
- New Orleans's first-ever benchmarking ordinance took effect: buildings 50,000 sq ft and larger began complying January 1, 2026 (first-year penalties waived).
- California, for the 2026 cycle, directs owners of buildings inside a local ordinance (such as Los Angeles EBEWE) to file through the city rather than the state. ENERGY STAR Portfolio Manager, the reporting backbone for nearly every law below, is moving from the EPA to the Department of Energy but remains fully operational.
The deadline calendar: July 2026 through December 2027
Dates are the compliance or reporting deadline for the covered building class shown. Where a 2026 deadline has already passed as of publication, the next recurring deadline is listed.
The rest of 2026
| Deadline | Jurisdiction | What is due |
|---|---|---|
| Aug 15, 2026 | Boston | BERDO annual energy + water report (extended from May 15) |
| Aug 29, 2026 | New York City | LL97 CY2025 emissions report, extension window closes |
| Sep 1, 2026 | Boston | BERDO Building Portfolio, Individual Compliance Schedule, and Hardship applications |
| Sep 30, 2026 | Philadelphia | BEPP tune-up report, buildings over 200,000 sq ft |
| Oct 31, 2026 | Boston | MA Class I REC purchase deadline for the 2025 emissions standard |
| Nov 1, 2026 | Colorado | Building Performance Colorado benchmarking report + fee (enforcement active) |
| Dec 1, 2026 | Los Angeles | EBEWE Audit + Retro-Commissioning, Building IDs ending 0 or 1 |
| Dec 31, 2026 | Washington DC | BEPS Cycle 1 compliance period ends (buildings over 50,000 sq ft) |
| Dec 31, 2026 | New York City | LL87 Energy Efficiency Report, tax blocks ending in 6 |
2027
| Deadline | Jurisdiction | What is due |
|---|---|---|
| Apr 1, 2027 | Washington DC | BEPS Completed Actions Report (Cycle 1) |
| May 1, 2027 | New York City | LL84 benchmarking (CY2026) and LL97 emissions report (CY2026) |
| May 1, 2027 | San Francisco | Annual energy benchmark (note: May 1, not April 1) |
| May 1, 2027 | San Jose | Annual benchmarking; Beyond Benchmarking for the assigned cohort |
| May 1, 2027 | Washington DC | Third-party verified benchmarking report |
| May 4, 2027 | St. Louis | BEPS standard, affordable housing and houses of worship |
| May 31, 2027 | New Orleans | Annual benchmarking (buildings 20,000 sq ft and larger now covered) |
| Jun 1, 2027 | California | AB 802 state benchmarking (buildings over 50,000 sq ft) |
| Jun 1, 2027 | Los Angeles | EBEWE annual benchmarking (CY2026 data) |
| Jun 1, 2027 | Chicago | Annual benchmarking (buildings over 50,000 sq ft) |
| Jun 1, 2027 | Denver | Energize Denver benchmarking + data verification |
| Jun 1, 2027 | Seattle | Annual benchmarking; BEPS third-party verification begins |
| Jun 1, 2027 | Washington State | Clean Buildings Tier 1, 90,000 to 220,000 sq ft |
| Jun 30, 2027 | Philadelphia | Annual benchmarking (buildings over 50,000 sq ft) |
| Jul 1, 2027 | New Jersey | Statewide CEA benchmarking (buildings over 25,000 sq ft) |
| Jul 1, 2027 | Washington State | Clean Buildings Tier 2, 20,000 to 50,000 sq ft + multifamily |
| Nov 1, 2027 | Colorado | Building Performance Colorado benchmarking (baseline-year switch deadline) |
| Dec 1, 2027 | Los Angeles | EBEWE Audit + Retro-Commissioning, Building IDs ending 2 or 3 |
The two deadlines most likely to be missed
Los Angeles EBEWE Audits and Retro-Commissioning, December 1, 2026. This five-year obligation applies to LADBS Building IDs ending in 0 or 1. It requires a Declaration of Completion signed in wet ink by a California-licensed professional, the registration window opens no earlier than August 1, and exemption paths (ENERGY STAR certification, a 15% source-EUI reduction) must be pursued months ahead. It is not a form you file the week it is due.
New York City Local Law 97, the 2030 step. Enforcement is now real: 93% of covered properties filed their first emissions reports, and the city has begun mailing Notices of Deficiency to roughly 1,400 that did not. Based on 2024 data, under 10% of buildings exceed today's 2024 to 2029 cap, but roughly 57% are projected to exceed the stricter 2030 cap. The work to close that gap takes years, not weeks.
Penalties, stated correctly
Penalty exposure varies by more than 100 times across these programs, and several are widely misquoted. A few that matter:
- New York City LL97: $268 per metric ton of CO2e over the building's limit, per year, plus $0.50 per square foot per month for failing to file.
- Los Angeles EBEWE: a $202 non-compliance fee (not "$202 per day," as some vendor pages state). Left unpaid, it grows: a 250% late charge after 30 days, then 12% annual interest after 60 days. Paying it does not make the building compliant.
- Washington State Clean Buildings: up to $5,000 plus $1.50 per square foot of floor area, which for a large building runs into six figures for a full year of non-compliance.
- Boston BERDO: an alternative compliance payment of $234 per metric ton of CO2e, set in the ordinance and reviewed every five years.
How to use this calendar
Find every city where you hold covered square footage, note the next date in each, and work backward: audits and retro-commissioning need lead time, exemption filings have their own earlier deadlines, and utility data can take weeks to obtain. If a compliance letter arrives from a third party, verify it directly with the program; Washington State and Austin have both warned owners about misleading vendor mail. Vert files these reports across every jurisdiction on this list; if you want your portfolio mapped against it, that is what a portfolio assessment does.