Whether a U.S. energy benchmarking or building performance law applies to your building almost always comes down to two facts: which jurisdiction the building sits in, and its gross floor area. The cutoffs vary more than most owners expect. Denver's lighter tier reaches down to 5,000 sq ft, while Washington State's first Clean Buildings wave started at 220,000 sq ft. Most cities land at 20,000 to 50,000 sq ft. This guide lists the verified threshold and annual deadline for 30 jurisdictions, checked against primary government sources in July 2026.
City-by-city thresholds and deadlines
Compliance below means the benchmarking or reporting obligation, the layer that applies first and to the most buildings. Performance standards (emissions or EUI targets) often sit on top of these same thresholds; see our 2026 BPS owner's guide for that layer.
| Jurisdiction | Who must comply | Annual deadline |
|---|---|---|
| New York City (LL84) | Over 25,000 sq ft; 100,000+ sq ft combined on shared tax lots or condo boards | May 1 |
| Los Angeles (EBEWE) | Private buildings 20,000+ sq ft; city-owned 7,500+ sq ft | June 1 |
| California statewide (AB 802) | Over 50,000 sq ft with no residential units or 17+ units | June 1 |
| San Francisco | Non-residential 10,000+ sq ft; multifamily 50,000+ sq ft | May 1 |
| San Jose | Nonresidential and multifamily 20,000+ sq ft | May 1 |
| San Diego | Over 50,000 sq ft (multifamily also needs 17+ residential accounts) | June 1 |
| Sacramento | No city ordinance in force; state AB 802 applies | June 1 (state) |
| West Hollywood | Over 20,000 sq ft (reporting began 2026) | Per program rollout |
| Boston (BERDO) | Non-residential 20,000+ sq ft; residential 15+ units | May 15 (extended to Aug 15 for 2026) |
| Cambridge (BEUDO) | Non-residential 25,000+ sq ft (tiered); residential 50+ units | May 1 |
| Washington, DC | Over 10,000 sq ft | May 1 |
| Montgomery County, MD | 25,000+ sq ft (county program; exempt from state BEPS) | June 1 |
| Maryland statewide (BEPS) | 35,000+ sq ft excluding parking | June 1 (June 30 for 2026) |
| Denver (Energize Denver) | 25,000+ sq ft full benchmarking; 5,000-24,999 sq ft lighting or renewable energy rules | Annual (see program portal) |
| Colorado statewide (BPC) | 50,000+ sq ft | Nov 1 |
| Boulder | Commercial and industrial 20,000+ sq ft (10,000+ sq ft if first permitted on or after Jan 31, 2014) | June 1 |
| Chicago | 50,000+ sq ft | June 1 |
| Evanston, IL | 20,000+ sq ft (condos exempt below 50,000 sq ft) | June 30 |
| Seattle | Non-residential and multifamily over 20,000 sq ft | June 1 |
| Washington State (Clean Buildings) | Tier 1: over 50,000 sq ft phased 2026-2028; Tier 2: 20,000-50,000 sq ft and multifamily over 20,000 sq ft from 2027 | Tier 1: June 1 by size tier; Tier 2: July 1, 2027 |
| Portland, OR | Commercial 20,000+ sq ft | April 22 |
| Philadelphia | Commercial and multifamily 50,000+ sq ft | June 30 |
| Atlanta | Over 25,000 sq ft | July 1 |
| Minneapolis | Commercial and multifamily 50,000+ sq ft | June 1 |
| St. Louis | 50,000+ sq ft, all major property types | May 1 (Dec 31 for municipal) |
| Kansas City, MO | 50,000+ sq ft (municipal 10,000+ sq ft) | May 1 |
| New Orleans | 50,000+ sq ft now; 20,000+ sq ft from Jan 1, 2027 | May 31 |
| New Jersey statewide (CEA) | Commercial over 25,000 sq ft | July 1 (first reports were due July 1, 2026) |
| Austin, TX (ECAD) | Commercial 10,000+ sq ft annual rating; multifamily 5+ units audit at year 10 | June 1 (commercial) |
| Miami (BE305) | 20,000+ sq ft and 5+ units (City of Miami only) | June 30 |
The traps that catch multi-city owners
- San Francisco is two-tier. Non-residential compliance starts at 10,000 sq ft, but multifamily does not start until 50,000 sq ft. Applying one number to both is a common error.
- Washington, DC is at 10,000 sq ft now. The threshold stepped down over time, and older references still citing 25,000 sq ft are stale.
- NYC has two different aggregation rules. Benchmarking (LL84) aggregates buildings on a shared tax lot at 100,000 sq ft; the LL97 emissions law aggregates at 50,000 sq ft. Same lot, different laws, different cutoffs.
- Montgomery County is its own program. Under Maryland's HB 49, buildings there are exempt from the state BEPS and follow the county's 25,000 sq ft rule instead of the state's 35,000 sq ft rule.
- Miami's mandate is the city's, not the county's. BE305 covers City of Miami buildings at 20,000+ sq ft with 5+ units; Miami-Dade County runs only a voluntary challenge.
- Austin's multifamily rule is age-triggered, not annual. Properties with 5+ units owe a specialized audit in the year the building turns 10, while the annual June 1 rating applies to commercial buildings of 10,000+ sq ft.
- Sacramento has no city ordinance. Owners there report under the state's AB 802 at over 50,000 sq ft, due June 1.
- New Jersey's first statewide deadline has already passed. Commercial buildings over 25,000 sq ft owed their first CEA benchmarking reports on July 1, 2026.
Below the threshold today does not mean exempt tomorrow
Several programs step down to smaller buildings on a published schedule. New Orleans expands from 50,000 to 20,000 sq ft on January 1, 2027. Washington State's Tier 2 pulls in 20,000 to 50,000 sq ft buildings and all multifamily over 20,000 sq ft with reports due July 1, 2027. Washington, DC's performance standard reaches buildings over 25,000 sq ft in its 2028 cycle and over 10,000 sq ft in 2034. Cambridge's 25,000 to 100,000 sq ft non-residential buildings must begin cutting emissions in 2030. If a building sits just under a local threshold, the right question is not whether it is exempt, but when that changes.
What to do with this table
- Pull gross floor area for every building from your rent roll or assessor records, and match each one against its jurisdiction's row.
- Flag anything within 20% of a threshold and anything in a step-down city, then diary the change dates.
- Confirm against the program page before filing. Deadlines moved in 2026 in Boston and Maryland, Seattle waived its 2025-data fines, and thresholds are amended more often than owners expect. The sources below are the authoritative pages.
Filing benchmarking reports in jurisdictions like these is Vert Energy Group's core work, and a free portfolio assessment will map every building you own against the thresholds above, then show what is due and when.