As May 1 approaches, owners face a dense lineup of compliance deadlines tied to the city’s push for safer, greener buildings. Four separate local laws, some newly in force and others ongoing, all share the same due date.

This year marks the first mandatory reporting date under Local Law 97, the city’s sweeping climate legislation targeting building emissions. At the same time, owners must meet existing requirements under Local Laws 84 and 88, including energy benchmarking, lighting upgrades, and submetering attestations. And while Local Law 157 doesn’t require a formal filing, it carries consequences for failure to install mandated natural gas detectors.

To help you prepare for the cluster of overlapping compliance deadlines, we’ll cover what you need to know about each law’s specific requirements, the types of buildings affected, how to navigate the city’s filing systems, and what penalties may apply.

Local Law 97: Greenhouse Gas Emissions Reduction

After years of anticipation, May 1 is the first-ever reporting deadline for Local Law 97, New York City’s landmark climate legislation aimed at drastically cutting greenhouse gas emissions in buildings over 25,000 square feet. The goal of the law is to reduce the emissions produced by the city’s largest buildings by 40 percent by 2030 and to net zero by 2050.

Compliance paths. Buildings that include rent-regulated housing are not exempt from the requirements of Local Law 97 but may be treated differently under the two articles that make up the law as outlined in Title 28 of the NYC Administrative Code:

• Article 320 establishes Building Energy and Emissions Limits for buildings starting in 2024 and outlines the implementation of such limits; and
• Article 321 establishes Energy Conservation Requirements for Certain Buildings that are not covered under Article 320.

Article 320 applies to a broader range of buildings, including those with fewer rent-regulated units, and Article 321 applies to buildings with more than 35 percent rent-regulated units. The Article 320 classification covers most buildings larger than 25,000 gross square feet (GSF) or on lots with multiple buildings totaling over 50,000 GSF. Article 320 applies to general building types such as residential, commercial, or industrial buildings that don’t meet the more specific requirements of Article 321. Also, buildings with one, but no more than 35 percent, rent-regulated units fall under Article 320 after 2026.

Article 321 buildings have the same size thresholds as Article 320 and are either houses of worship or meet certain categories of low-income housing or rent-regulated accommodations. For large rent-regulated buildings, this category specifically applies to buildings where more than 35 percent of the units are subject to rent regulation. These buildings remain under Article 321 as long as they maintain this level of rent-regulated units. It’s important to note that buildings initially covered by Article 321 may shift to Article 320 if the proportion of rent-regulated units drops below 35 percent.

For applicable rent-regulated buildings under Article 321, owners can comply by following what DOB refers to as a prescriptive pathway for compliance. Instead of meeting emissions targets, owners can comply by implementing specific energy conservation measures rather than simply tracking emissions and meeting emission limits. There is also the option for a performance-based pathway, but the prescriptive measures are more emphasized in Article 321 to meet energy efficiency goals.

Deadline. For buildings covered under Article 320, the first annual emissions report is due on May 1, using 2024 calendar year data. Miss the deadline, and you risk fines of $0.50 per square foot per month until the report is filed. The stakes are high as noncompliant buildings not only face reporting fines, but also emissions fines of $268 per ton of CO₂ over the limit for Article 320 buildings. If needed, owners can apply for an extension by June 30, delaying the reporting deadline to Aug. 29.

For rent-regulated properties with more than 35 percent rent-stabilized units (Article 321), emissions tracking doesn't apply. Instead, these buildings use the prescriptive compliance pathway that required specific energy conservation measures (ECMs) by Dec. 31, 2024. For these buildings, the one-time Article 321 report, documenting those upgrades, must be filed by May 1.

Online reporting portal. DOB recently launched a compliance reporting portal at nyc.beam-portal.org. The portal allows owners, owner representatives, and service providers, including registered design professionals and qualified retro-commissioning agents, to file LL97 compliance reports on behalf of covered building owners.

According to a DOB webinar, it’s important to note that filing is a multi-day process as you’ll need to navigate three separate systems to complete the filing. Access to the online building energy analysis manager (BEAM) reporting portal is gated by steps that must be completed in the right order. First comes payment of the Local Law 97 filing fee through DOB NOW. Then, you’ll have to ensure your building’s energy data is uploaded and shared via ENERGY STAR Portfolio Manager (ESPM). Only then will the BEAM portal unlock for you and that typically takes a day, since the systems sync overnight.

Although the deadline to submit this year’s compliance report is May 1, there's a 60-day grace period through June 30, 2025. Owners also have until June 30, 2025, to apply in the reporting portal for an extension to the reporting deadline to Aug. 29 – where a registered design professional or qualified retro-commissioning agent states that such professional has been hired to complete the report. Owners don't need to demonstrate a contract has been executed by a particular date to apply for the extension. With the launch of the portal, the period to submit LL97 compliance reports is effectively six months until Aug. 29.

Local Law 88: Lighting Upgrades and Submetering

Also due on May 1 is proof of compliance with Local Law 88, which requires energy-efficient lighting upgrades in the common areas of residential buildings larger than 25,000 square feet. These common area spaces include areas such as lobbies, hallways, service areas, basements, mechanical rooms, laundry rooms, and utility closets) to meet current NYC Energy Conservation Code standards. The same law mandates electrical submeters in commercial tenant spaces over 5,000 square feet.

Required reports. A professional attestation by a licensed electrician or registered design professional must confirm that all lighting complies with NYC Energy Code standards. This form certifies that the lighting system of the entire building has been inspected and upgrades have been implemented in accordance with the law by a registered design professional or a licensed master or special electrician.

Deadline. Owners will be required to pay a $115 filing fee to submit LL88 reports by May 1. The $115 filing fee includes both lighting and submetering compliance reports. For buildings that are filing LL97, there is no additional filing fee for LL88 reports. Report submission for LL88 compliance is through the BEAM platform.

Penalties. Failing to file this attestation of compliance carries a $1,500 annual fine. And penalties for failure to install submeters in covered tenant spaces in commercial buildings will be $500 for each space, assessed annually until all submeters are installed.

Local Law 84: Benchmarking Data Submission

While Local Law 97 and Local Law 88 represent first-time sustainability related filings for this year, Local Law 84, which requires annual benchmarking data submission for large buildings, has been in effect since 2010. This annual benchmarking law also carries a May 1 deadline.

Large building applicability, requirements. Local Law 84 requires owners of large buildings to annually measure their energy and water consumption in a process called benchmarking. LL84 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.

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. Applicable buildings of this size are also subject to the carbon reduction requirements in Local Law 97.

Compliance steps. The city has released its 2025 Covered Buildings List. It can be found at https://www.nyc.gov/assets/buildings/pdf/benchmarking_cbl_compliance_2025.pdf. 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.

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 (www.energystar.gov/buildings/benchmark).

Next, you’ll 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.

For water data, the Department of Environmental Protection (DEP) provides all water consumption information to properties eligible and covered under LL84. Only covered properties that have had an Automatic Meter Reader (AMR) installed for at least the entire calendar year will be 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.

Then you’ll record your energy and water usage in Portfolio Manager. If you’re unfamiliar with using Portfolio Manager, you can study training materials found at www.energystar.gov/buildings/training.

The last step is to submit usage data to the city by May 1 through Portfolio Manager. Before submitting your report, review the benchmarking checklist at www.nyc.gov/assets/buildings/pdf/benchmarking_checklist.pdf to ensure that you’ve completed all the necessary steps. Once you’ve uploaded your data and received an automatic email confirmation from Portfolio Manager, you will have successfully complied with the NYC Benchmarking Law. For help with benchmarking submissions, you can contact the NYC Sustainability Help Center at HELP@NYCsustainability.org or (212) 566-5584, Monday through Friday, from 9 a.m. to 5 p.m.

Penalties. Failure to report by May 1 triggers a $500 fine, with additional $500 penalties every quarter, up to $2,000 annually, until the data is submitted.

Local Law 157: Gas Detectors, No Filing Required

Unlike the other laws, Local Law 157 doesn’t require a filing, but compliance is mandatory. All residential buildings with natural gas appliances must have natural gas detectors installed in every unit by May 1, 2025. Buildings that don't have gas piping or gas service aren't required to install gas detectors.

Gas detector requirements. The gas detectors that comply with Local Law 157 are natural gas detectors that meet the requirements of NFPA 715-2023. The alarm must be labeled with the name of the manufacturer and be labeled with either UL1484 or UL2075. The devices can be hardwired, plugged into a constant power source, or battery-powered by a listed monitored low-power radio wireless system.

Location requirements. If your apartment has a gas-burning appliance, the detector must be installed in the same room as the appliance. The alarm must be located at least 3 feet, but not more than 10 feet, from the appliance, measured horizontally. And the gas alarm must be installed on either the ceiling or a wall. If it’s installed on a wall, the alarm must be within 12 inches of the ceiling.

If a space doesn't allow for installation at least 3 feet from a gas-burning appliance, the alarm must be placed in accordance with the manufacturer’s instructions or NFPA 715 location requirements.

Installer requirements. Hard-wired detectors require installation by a licensed electrician who obtains all required permits. Gas detectors powered by a battery or a plug-in power source can be installed by building owners, maintenance personnel, or tenants. The detectors must meet strict location and performance standards set by the city and NFPA 715, including placement within one foot of the ceiling and within 10 feet of any gas appliance.

No filing required. While no paperwork needs to be submitted, enforcement may come through inspections or tenant complaints, and violations could be serious, not just financially, but in terms of liability.