Local Law 84 Introduction
New York City Local Law 84 (LL84), also known as the NYC Benchmarking Law, requires covered buildings to annually measure and report their energy and water consumption. Enacted in 2009 and later expanded by Local Law 133, the law provides building owners, tenants, and the City with greater transparency into building energy performance.
Benchmarking allows property owners to understand how their buildings use energy and water, compare performance over time, identify inefficiencies, and make informed decisions about energy improvements.
For 2026 compliance, properties identified as subject to LL84 on the current Covered Buildings List must report their 2025 calendar-year energy consumption and applicable water consumption by May 1, 2026.
This guide explains who must comply with Local Law 84, annual benchmarking requirements, filing deadlines, penalties, and how SFE can help manage the process.
What Is Local Law 84?
Local Law 84 requires owners of covered New York City buildings to annually benchmark their energy and applicable water consumption using the U.S. Environmental Protection Agency’s ENERGY STAR Portfolio Manager® (ESPM).
Benchmarking creates a standardized method for evaluating building performance and can help owners:
- Track annual energy and water consumption
- Compare building performance over time
- Identify inefficient building operations and systems
- Discover opportunities to reduce utility costs
- Support energy-efficiency and decarbonization planning
- Maintain compliance with related NYC sustainability requirements
NYC DOB explains that benchmarking is intended to identify underperforming buildings and encourage operational and maintenance improvements that can reduce costs and greenhouse gas emissions.
History and Purpose of Local Law 84
Local Law 84 was enacted in 2009 as part of New York City’s Greener, Greater Buildings Plan.
The law originally focused on larger properties. In 2016, Local Law 133 expanded the benchmarking requirements to include additional mid-sized buildings, significantly increasing the number of NYC properties required to report annual energy and water consumption.
Today, benchmarking serves as an important foundation for New York City’s broader building-energy policies. The data gives building owners a clearer understanding of their properties’ performance and can help inform future energy-efficiency and emissions-reduction strategies.
Who Is Required to Comply with Local Law 84?
According to current NYC DOB requirements, covered buildings generally include:
- Individual buildings exceeding 25,000 gross square feet
- Two or more buildings on the same tax lot that together exceed 100,000 gross square feet
- Two or more condominium buildings governed by the same board of managers that together exceed 100,000 gross square feet
- City-owned buildings, subject to applicable requirements
Building coverage is determined based on NYC Department of Finance records and the annual Covered Buildings List (CBL).
Because a property’s status can change from year to year, DOB recommends reviewing the most current Covered Buildings List annually rather than assuming that a previous year’s status still applies.
Local Law 84 Exceptions
Certain properties are excluded from the definition of a covered building, including:
- Certain City-owned buildings participating in the Tenant Interim Lease Apartment Purchase Program
- Tax Class 1 properties, which generally include most one- to three-family homes
- Certain qualifying garden-style apartments, when applicable requirements are satisfied and certified by a Registered Design Professional
Other circumstances, such as demolition, certain new-building situations, or buildings that have not yet received their first Temporary Certificate of Occupancy, may qualify for temporary reporting exemptions subject to DOB requirements.
What Are the Local Law 84 Requirements?
Building owners subject to LL84 must complete annual benchmarking for the previous calendar year’s energy consumption and applicable water consumption.
The primary requirements include:
- Confirm Building Applicability
Review the current Covered Buildings List to determine whether the property is required to benchmark. - Collect Building Information
Gather required property information, including gross floor area, building use, occupancy characteristics, and other relevant data. - Collect Energy & Water Consumption Data
Obtain whole-building utility consumption information for the applicable reporting year. - Enter & Verify Data in ENERGY STAR Portfolio Manager®
Enter building characteristics and utility consumption into ESPM and review the information for accuracy and completeness. - Submit Benchmarking Data to NYC
Complete the required submission through ENERGY STAR Portfolio Manager® by the applicable annual deadline.
For properties identified by DOB as requiring DEP water reporting, applicable water consumption data must also be included.
Local Law 84 Deadline
The annual Local Law 84 benchmarking deadline is May 1.
For the current 2026 compliance year, covered properties are required to submit benchmarking information for 2025 calendar-year energy and applicable water consumption by May 1, 2026.
If a compliant report is not submitted by May 1, additional quarterly compliance deadlines occur on:
| Deadline | Potential Penalty |
|---|---|
| May 1 | $500 |
| August 1 | $500 |
| November 1 | $500 |
| February 1 of the following year | $500 |
| Maximum Annual Penalty | $2,000 |
DOB may issue a $500 penalty for each missed quarterly deadline until a compliant benchmarking report is submitted, up to $2,000 per year.
How to Comply with Local Law 84
The benchmarking process can involve multiple utility accounts, meters, building-use classifications, and property information. Accurate data collection is essential to completing the submission correctly.
Step 1: Check the Covered Buildings List
Review the current NYC Covered Buildings List (CBL) using the property’s Borough, Block and Lot number (BBL).
The list is updated annually, so building owners should confirm their compliance status each year.
Step 2: Set Up ENERGY STAR Portfolio Manager®
Create or access the building’s ENERGY STAR Portfolio Manager® account and verify that the property profile accurately reflects the building.
Step 3: Collect Utility Data
Gather whole-building energy consumption information for electricity, natural gas, steam, fuel oil, and other applicable energy sources.
If the property is required to report water consumption, the appropriate water data must also be obtained and entered.
Step 4: Review Property Information
Verify key building characteristics, including property type, gross floor area, occupancy, and other information required by ENERGY STAR Portfolio Manager®.
Accurate property information is important because incorrect inputs can affect benchmarking results and ENERGY STAR scores.
Step 5: Review and Submit
Review the benchmarking data for missing information, errors, and inconsistencies before submitting it to New York City.
After submission, building owners should confirm that the filing has been successfully received and address any deficiencies that could prevent the property from achieving compliant status.
Why Is Benchmarking Important?
Local Law 84 is more than an annual reporting requirement. Benchmarking provides building owners with useful information about how their properties perform.
Identify Energy Inefficiencies
Tracking energy consumption from year to year can reveal unusual increases, inefficient equipment, operational problems, or other opportunities for improvement.
Reduce Operating Costs
Benchmarking can help owners identify areas where energy and water consumption may be reduced, potentially lowering utility and operating expenses.
Support Capital Planning
Historical energy-performance data can help owners prioritize HVAC upgrades, lighting improvements, controls, envelope improvements, and other energy conservation measures.
Prepare for Other NYC Energy Laws
Benchmarking data also plays an important role in other NYC sustainability requirements, including Local Law 33 energy grading and broader building emissions planning.
Local Law 84 and Related NYC Local Laws
Local Law 84 works alongside several other NYC building-energy requirements.
Local Law 133 expanded the benchmarking requirements to additional mid-sized buildings, including applicable buildings exceeding 25,000 square feet.
Local Law 33 requires applicable buildings to publicly display an annual Energy Efficiency Score and Grade based on benchmarking information.
Local Law 97 establishes greenhouse gas emissions limits for covered buildings. Maintaining accurate energy-consumption records can help building owners better understand their emissions profile and plan for future compliance.
Together, these requirements make energy data increasingly important to building operations, regulatory compliance, and long-term capital planning.
Local Law 84 Penalties
Failure to submit a compliant benchmarking report by the annual deadline may result in a $500 DOB penalty.
Continued failure to comply may result in additional $500 penalties at the August 1, November 1, and February 1 quarterly deadlines, for a maximum of $2,000 per year.
Submitting information does not necessarily mean the building has achieved compliance—the benchmarking report must be sufficiently complete and compliant with DOB requirements.
How SFE Can Help with Local Law 84
Managing annual benchmarking can become time-consuming, particularly for owners and property managers responsible for multiple buildings, utility accounts, and meters.
SFE provides comprehensive Local Law 84 benchmarking services from start to finish. Our team can assist with building applicability review, utility data collection, ENERGY STAR Portfolio Manager® setup and management, data verification, annual submission, and compliance follow-up.
Beyond the annual filing, our energy professionals can help identify unusual energy consumption, potential efficiency opportunities, and other NYC energy compliance requirements affecting your property.
Whether you manage a single building or an entire portfolio, SFE can help simplify benchmarking and keep your properties on track with annual NYC requirements.
Conclusion
Local Law 84 benchmarking is an annual compliance requirement and an important building-management tool. Accurate energy and water data can help property owners understand building performance, identify opportunities for improvement, and support compliance with New York City’s broader energy and sustainability requirements.
With annual reporting required every year, maintaining accurate records and preparing early can help avoid last-minute complications and costly violations.
Let SFE manage your Local Law 84 benchmarking from start to finish—so you can stay compliant, understand your building’s performance, and focus on managing your property.
