NYC Local Law Compliance Calendar: Key Deadlines for Building Owners
New York City building owners face a growing number of inspection, energy, emissions, and reporting requirements. With Local Laws covering everything from energy benchmarking and greenhouse gas emissions to façade inspections and parking structures, keeping track of compliance deadlines can quickly become complicated.
Missing a required filing, inspection, or posting deadline can also lead to violations and penalties. For property owners and managers overseeing multiple buildings, maintaining an accurate compliance calendar is therefore an important part of building operations.
This guide provides an overview of several major NYC building compliance requirements, including Local Law 11, Local Law 33, Local Law 84, Local Law 87, Local Law 88, Local Law 97, Local Law 126, and annual parapet observations.
NYC Local Law Compliance Calendar at a Glance
| Requirement | Key Deadline | Frequency |
|---|---|---|
| Local Law 84 – Benchmarking | May 1 | Annually |
| Local Law 97 – Emissions Reporting | May 1 for applicable Article 320 buildings | Annually |
| Local Law 33 – Energy Grade Posting | Within 30 days after October 1 | Annually |
| Local Law 87 – Energy Audit & Retro-Commissioning | December 31 of applicable filing year | Every 10 years |
| Local Law 11 / FISP Cycle 10A | February 21, 2027 | Once per applicable five-year cycle |
| Local Law 11 / FISP Cycle 10B | February 21, 2028 | Once per applicable five-year cycle |
| Local Law 11 / FISP Cycle 10C | February 21, 2029 | Once per applicable five-year cycle |
| Local Law 126 – Cycle 1C Parking Structures | December 31, 2027 | Per inspection cycle |
| Annual Parapet Observation | December 31 | Annually |
Building-specific applicability should always be confirmed before relying on a general calendar. Covered-building lists, building characteristics, tax block numbers, community districts, and other factors can affect which requirements apply.
Local Law 84: Annual Energy and Water Benchmarking
Typical deadline: May 1 every year
Local Law 84 requires covered NYC buildings to annually benchmark their energy and water consumption using the U.S. Environmental Protection Agency’s ENERGY STAR Portfolio Manager.
The law generally applies to buildings exceeding 25,000 gross square feet, as well as certain groups of buildings on the same tax lot or condominium properties that collectively exceed the applicable threshold.
For the 2026 filing year, covered properties are required to report their 2025 calendar-year energy and water consumption by May 1, 2026.
Owners should begin gathering utility information well before the filing deadline. DOB recommends sharing the property with the City through ENERGY STAR Portfolio Manager at least 15 business days before May 1 to allow time to identify and correct potential errors.
Failure to submit satisfactory benchmarking data may result in violations and recurring quarterly penalties.
Important dates:
- May 1: Annual benchmarking deadline
- August 1: Subsequent compliance deadline
- November 1: Subsequent compliance deadline
- February 1: Final subsequent deadline in the following year
Local Law 33: Building Energy Efficiency Rating
Label available: October 1
Posting deadline: Within 30 days after October 1
Local Law 33 requires covered buildings to publicly display their annual Building Energy Efficiency Rating.
The rating is closely connected to Local Law 84 because the building’s energy efficiency score and grade are based on its annual benchmarking information.
Beginning October 1 each year, owners can access the applicable Building Energy Efficiency Rating label through the DOB NOW Public Portal. The label must then be printed and displayed in a conspicuous location near each public entrance within 30 days after October 1.
Owners should therefore treat LL33 and LL84 as related annual compliance tasks:
Benchmark by May 1 → Receive annual energy grade → Post the label after October 1.
Failure to properly display the required label may result in a DOB violation and a $1,250 fine.
Local Law 87: Energy Audits and Retro-Commissioning
Deadline: December 31 of the building’s applicable filing year
Local Law 87 requires covered buildings to periodically complete an energy audit and retro-commissioning and submit an Energy Efficiency Report (EER) to the City.
Unlike LL84, the filing is not required every year. The applicable filing year is determined by the last digit of the building’s tax block number.
For example:
| Last Digit of Tax Block | Filing Year |
|---|---|
| 6 | 2026 |
| 7 | 2027 |
| 8 | 2028 |
| 9 | 2029 |
| 0 | 2030 |
| 1 | 2031 |
| 2 | 2032 |
| 3 | 2033 |
| 4 | 2034 |
| 5 | 2035 |
The cycle then repeats every ten years.
For example, if a property’s tax block ends in 7, its next applicable filing year is 2027, and its Energy Efficiency Report would generally be due by December 31, 2027.
Because an energy audit and retro-commissioning can involve building inspections, equipment review, analysis, corrective measures, and documentation, owners should not wait until December to begin the process.
Local Law 11: FISP Cycle 10 Deadlines
New York City’s Façade Inspection and Safety Program (FISP), commonly referred to as Local Law 11, requires owners of buildings greater than six stories to have exterior walls and appurtenances periodically examined and to file an acceptable report with DOB.
Cycle 10 began on February 21, 2025 and is divided into three sub-cycles based on the last digit of the building’s block number.
Cycle 10A
Block numbers ending in: 4, 5, 6, or 9
Filing window: February 21, 2025 – February 21, 2027
Cycle 10B
Block numbers ending in: 0, 7, or 8
Filing window: February 21, 2026 – February 21, 2028
Cycle 10C
Block numbers ending in: 1, 2, or 3
Filing window: February 21, 2027 – February 21, 2029
Building owners should identify their assigned sub-cycle early enough to allow time for inspection, close-up examination requirements, reporting, and any repairs that may become necessary.
Local Law 126: Parking Structure Inspections
Local Law 126 established periodic inspection requirements for certain parking structures in New York City.
Like FISP, the parking structure inspection program operates through cycles and sub-cycles. However, the applicable sub-cycle is based on the parking structure’s Community District, rather than the last digit of its tax block.
For Cycle 1:
- Sub-Cycle 1A: Manhattan Community Districts 1–7 — filing period ended December 31, 2023
- Sub-Cycle 1B: Manhattan Community Districts 8–12 and Brooklyn Community Districts — filing period ended December 31, 2025
- Sub-Cycle 1C: Bronx, Queens, and Staten Island Community Districts — filing period ends December 31, 2027
Owners of parking structures subject to Cycle 1C should therefore be preparing for the December 31, 2027 deadline.
Parking structure inspections should be planned well in advance because identified conditions may require maintenance, repairs, additional investigation, or follow-up documentation.
Local Law 88: Lighting and Sub-Metering
Local Law 88 requires covered buildings to comply with requirements relating to lighting system upgrades and electrical sub-metering.
The law generally covers buildings exceeding 25,000 gross square feet, as well as certain larger groups of buildings on the same tax lot or under common condominium management.
The principal compliance requirements took effect in 2025. Covered lighting systems were required to comply with applicable lighting standards, while covered tenant spaces became subject to electrical sub-metering requirements.
LL88 reporting is handled through the City’s BEAM platform. Building owners that remain subject to filing requirements or need to address outstanding compliance should verify their building’s current status rather than assuming that the passing of the original 2025 deadline eliminated the obligation.
Local Law 97: Greenhouse Gas Emissions
Annual reporting deadline: May 1
Local Law 97 establishes greenhouse gas emissions requirements for many larger New York City buildings.
For most buildings subject to Article 320, annual greenhouse gas emissions reports are required. The first reporting deadline was May 1, 2025, covering calendar-year 2024 emissions. Subsequent reports are generally due May 1 each year.
For the 2026 filing year, covered buildings subject to the applicable Article 320 pathway are required to report calendar-year 2025 emissions by May 1, 2026.
Not every covered building follows the same compliance pathway. For example, certain qualifying rent-regulated properties are subject to the 2026 pathway, with emissions requirements beginning in calendar year 2026 and their first report due May 1, 2027.
Owners should therefore verify the building’s designated compliance pathway rather than relying solely on building size.
This becomes increasingly important as NYC moves toward more stringent emissions limits beginning in 2030. Owners should evaluate building performance early enough to identify whether energy efficiency upgrades, HVAC improvements, electrification, controls, envelope improvements, or other measures may be needed.
Annual Parapet Observation
Deadline: December 31 every year
Beginning in 2024, NYC requires annual observations of qualifying building parapets.
The requirement generally applies to buildings with parapets fronting the public right-of-way, regardless of building height, with certain exceptions such as detached one- or two-family homes and buildings where a fence or other barrier prevents access to the exterior wall.
The observation must be completed annually, with the owner maintaining the required report by December 31.
Unlike some other NYC compliance programs, the parapet observation report is not routinely filed with DOB. Instead, the owner must maintain the report for at least six years and make it available to DOB upon request.
If an unsafe condition is discovered, additional notification and public-protection requirements may apply.
Why Building Owners Should Maintain a Compliance Calendar
NYC building compliance is increasingly interconnected.
A single property may simultaneously be subject to:
- LL84 annual benchmarking
- LL33 energy grade posting
- LL87 energy audit and retro-commissioning
- LL88 lighting and sub-metering requirements
- LL97 greenhouse gas emissions requirements
- LL11 façade inspections
- LL126 parking structure inspections
- Annual parapet observations
The deadlines are not all based on the same criteria. Some are annual, some depend on the tax block number, some depend on the building’s Community District, and others depend on a specific compliance pathway.
For owners managing multiple properties, relying on individual reminders can make it easy for a requirement to be overlooked.
A centralized compliance calendar should track, at minimum:
- Property address
- BBL and BIN
- Applicable Local Laws
- Filing or inspection deadline
- Current compliance status
- Required inspection or engineering work
- Responsible party
- Filing confirmation
- Upcoming cycle or renewal date
2026–2029 Deadlines Building Owners Should Be Watching
Several important deadlines are approaching over the next few years.
2026
- May 1, 2026 — LL84 annual benchmarking
- May 1, 2026 — applicable LL97 annual reporting
- December 31, 2026 — applicable LL87 filings
- December 31, 2026 — annual parapet observation
- October 2026 — LL33 energy rating label posting period
2027
- February 21, 2027 — LL11/FISP Cycle 10A deadline
- May 1, 2027 — LL97 first reporting deadline for applicable 2026-pathway properties
- December 31, 2027 — LL126 Cycle 1C deadline
- December 31, 2027 — LL87 filing deadline for applicable tax blocks
2028
- February 21, 2028 — LL11/FISP Cycle 10B deadline
- December 31, 2028 — applicable LL87 deadline
2029
- February 21, 2029 — LL11/FISP Cycle 10C deadline
- December 31, 2029 — applicable LL87 deadline
Annual requirements such as LL84, applicable LL97 reporting, LL33 posting, and parapet observations continue during these years.
How SFE Engineering Can Help
Managing NYC Local Law compliance often requires coordination between building owners, property managers, engineers, contractors, utility providers, and City filing systems.
SFE Engineering provides compliance and engineering support for New York City properties, including:
- Local Law 97 compliance and emissions reporting
- Local Law 84 energy benchmarking
- Local Law 87 energy audits and retro-commissioning
- Local Law 88 lighting and sub-metering compliance
- Local Law 11/FISP façade inspection services
- Local Law 126 parking structure inspection support
- Local Law 33 energy efficiency rating compliance
- Annual parapet observations
- Energy audits and energy modeling
- Commissioning and retro-commissioning
- Building performance and energy-efficiency consulting
Building owners should begin planning before the applicable deadline, particularly when compliance may require inspections, engineering analysis, corrective work, or coordination with contractors.
Stay Ahead of Your Building’s Next Compliance Deadline
NYC Local Law requirements continue to evolve, and a building may be subject to multiple overlapping compliance programs. Knowing which laws apply, when the next deadline occurs, and what work must be completed beforehand can help owners avoid last-minute filings, violations, and unnecessary penalties.
If you are unsure which upcoming NYC Local Law deadlines apply to your property or portfolio, contact SFE Engineering to review your building’s compliance requirements and plan for upcoming inspections, filings, and energy-efficiency work.
This article is intended for general informational purposes. Requirements, deadlines, covered-building lists, and agency guidance may change. Building owners should confirm current requirements with the New York City Department of Buildings and appropriate qualified professionals.
