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NYC Energy Law Compliance: What Building Owners Should Know in 2026
A High-Level Compliance Overview of LL97, LL87, LL88, and LL84
New York City building owners and managers are facing a growing number of energy-related regulations, and it can be difficult to determine which rules apply to which properties. Local Laws 97, 87, 88, and 84 (below referred to as LL97, LL87, LL88, and LL84) were enacted with the goal of reducing carbon emissions and improving building performance, but they differ in scope, requirements, timelines, and types of properties affected.
As of December 31, 2025, the first official LL97 compliance period was completed, marking the beginning of emissions reporting and potential penalties. Reflecting on the first year of LL97 filings, Mariel Hoffman, PE, Director of Energy Engineering at EN‑POWER GROUP, said: “It had its challenges, but there was a lot of collaboration amongst providers in the industry and the DOB. Hopefully this sets the stage for future years of LL97 and opens building owners’ eyes to the reality of high penalties for 2030. They have to plan now and take steps.”
This article provides a high-level overview of these four local laws: what they are, who they apply to, why they exist, and what you can do now. The goal is clarity, so you can better understand the regulatory landscape and begin 2026 with accurate information.
Local Law 97: Carbon Emissions Limits
What Is LL97?
A part of NYC’s Climate Mobilization Act, LL97 was adopted in 2019 to reduce greenhouse gas emissions from large buildings and support the City government’s long-term goal of net-zero carbon emissions by 2050.
LL97 is designed to implement an ambitious emissions-reduction effort in stages, with five-year milestones that gradually tighten limits on buildings’ carbon output. Under LL97, emissions caps are set according to each building’s size and use, ensuring a structured and measurable path toward lower carbon emissions.
Who Does LL97 Apply To?
LL97 generally applies to:
- Most buildings larger than 25,000 sq. ft.
- Two or more buildings on the same tax lot—or condominium buildings governed by the same board of managers—with a combined total exceeding 50,000 sq. ft.
⚠️ Important Note: Coverage depends not only on size, but also on building classification: Some property types are able to pursue an alternative path to compliance (i.e., Article 321) , such as specific affordable housing categories and places of worship.
Why Does LL97 Exist?
At a citywide level, LL97 is intended to:
- Drive reductions in greenhouse gas emissions
- Encourage long-term building efficiency
- Improve overall building performance
What Can You Do Now?
Early planning expands your options and reduces long-term cost exposure. This can look like:
- Engaging with an experienced Registered Design Professional (RDP) to confirm your building’s emissions profile
- Understanding where penalties may exist both now and starting in 2030 when emissions limits get stricter
- Mapping potential reduction strategies early with consideration for captial planning
⚠️ Important Note: Specific requirements are determined by a building’s Borough-Block-Lot (BBL) and Building Identification Numbers (BINs). Check the DOB’s LL97 Covered Buildings List for eligibility.
2026 Deadline For LL97
We are now in the second year of required reporting. For most properties, compliance reports for 2025 are due by May 1, 2026. There is an automatic grade period through June 30, 2026 and an extension option extending to August 29, 2026. ⚠️ Important Note: Always confirm the current year’s deadline on the City’s official site before filing.
Local Law 87: Energy Audits & Retro-Commissioning
What Is LL87?
LL87 requires certain large buildings to complete periodic energy audits and retro-commissioning studies to evaluate how building systems are operating.
For covered properties, i.e., buildings required to comply in the current year, compliance includes completing an ASHRAE Level II Energy Audit and Retro-Commissioning study and submitting an Energy Efficiency Report to the DOB.
Who Does LL87 Apply To?
LL87 generally applies to:
- Most buildings larger than 50,000 sq. ft.
- Two or more buildings on the same tax lot—or condominium buildings governed by the same board of managers—with a combined total exceeding 100,000 sq. ft.
- Properties listed on the LL87 Covered Buildings List
Why Does LL87 Exist?
LL87 is designed to:
- Identify opportunities to reduce energy waste
- Surface opportunities for energy efficiency
- Improve system operations
- Support longer-term emissions-reduction planning
What Can You Do Now?
If your compliance year is approaching, schedule early (up to 4 years prior). If you recently completed LL87, you likely already have insight into ways your building can improve energy efficiency and reduce carbon emissions—those findings can help inform LL97 planning and capital decisions.
2026 Deadline For LL87
Compliance occurs once every 10 years and is based on the last digit of a building’s tax block number. The LL87 filing deadline for buildings with tax block numbers ending in 5 has been extended from December 2025 to March 31, 2026. Buildings with a tax block number ending in 6 are required to demonstrate compliance in 2026 must file by December 31, 2026. ⚠️ Important Note: The DOB may extend or amend these deadlines. Always confirm the current year’s deadline on the City’s official site before filing.
Local Law 88: Lighting and Submetering
What Is LL88?
LL88 focuses on lighting and controls upgrades as well as tenant electrical submetering in many large NYC buildings. The law requires covered properties to bring lighting systems into compliance with the NYC Energy Conservation Code (often through LED upgrades and controls) and to install submeters in qualifying commercial tenant spaces.
Who Does LL88 Apply To?
LL88 generally applies to
- Most buildings larger than 25,000 sq. ft.
- Two or more buildings on the same tax lot—or condominium buildings governed by the same board of managers—with a combined total exceeding 100,000 sq. ft.
- Properties listed on the LL88 Covered Buildings List
Why Does LL88 Exist?
LL88 aims to:
- Improve lighting efficiency and reduce energy consumption
- Increase visibility of tenant energy use
- Support broader building performance goals of energy and carbon emissions reduction
What Can You Do Now?
Engage with an experienced Registered Design Professional (RDP) to confirm your building’s compliance status, complete any required upgrades, and submit compliance. Do not assume prior upgrades alone satisfy compliance requirements.
2026 Deadline For LL88
LL88 is a one-time compliance filing, with an annual submission deadline of May 1 until compliance is filed. ⚠️ Important Note: The DOB may extend or amend these deadlines. Always confirm the current year’s deadline on the City’s official site before filing.
Local Law 84: Energy Benchmarking
What Is LL84?
LL84—together with LL133 which amended it—make up the NYC Benchmarking Laws. It requires owners of buildings that meet the criteria outlined in the law to annually measure their energy and water consumption through a process called benchmarking. The law standardizes this process by requiring building owners to use the EPA’s online benchmarking tool, ENERGY STAR® Portfolio Manager®, to enter and submit their annual usage data to the City. The benchmarking data is then shared with the DOB via the BEAM portal.
Who Does LL84 Apply To?
LL84 generally applies to:
- Most buildings larger than 25,000 sq. ft.
- Two or more buildings on the same tax lot—or condominium buildings governed by the same board of managers—with a combined total exceeding 100,000 sq. ft.
- Properties listed on the City’s Covered Buildings List
Why Does LL84 Exist?
Benchmarking is intended to:
- Create transparency around annual energy and water use
- Provide owners with comparative performance data that can help identify areas for upgrades
- Help buildings operate more efficiently
What Can You Do Now?
Verify that your 2025 data is complete and correctly submitted so you are not carrying errors into 2026.
2026 Deadline For LL84
Applicable building owners must comply with LL84 by May 1 of each year (unless otherwise extended by the City during a specified year). ⚠️ Important Note: The DOB may extend or amend these deadlines. Always confirm the current year’s deadline on the City’s official site before filing.
How These Local Laws Intersect
New York City’s energy regulations are designed to work together as part of a broader sustainability framework:
- LL84 benchmarks buildings to understand energy use intensity, energy trends, and emissions per fuel source; these foundational benchmarking data are used to support both LL97 emissions calculations and LL87 energy audits.
- LL87 audit findings may highlight upgrades that affect LL97 performance
- LL88 lighting improvements can contribute to lower overall energy use
Treating the laws as isolated checklists may lead to confusion, higher costs, rushed decisions, and missed opportunities to align compliance work with long-term capital planning and available incentives. Understanding how each requirement fits into the larger picture can help building owners better track obligations across reporting cycles.
Bonus: Tips for Financing Local Law Compliance Projects
Depending on building type, scope of work, and program availability, energy and carbon compliance work may qualify for certain forms of financial support. These can include:
- Tax credits
- Utility rebates
- Government incentives
- Grants
- Specialized financing programs
Eligibility and availability vary widely by property and project. We encourage buildings to consult qualified RDP experts to better understand which programs, if any, apply to their situation.
Get additional resources on each local law:
Key Takeaway
LL97, 87, 88, and 84 address different aspects of building energy performance: carbon emissions, audits, lighting systems, and benchmarking. Together, they form the backbone of New York City’s building sustainability regulations.
If you’d like help confirming your building’s status for the current year, our team can review applicable requirements with you.
Just give us a call at (914) 263-1199 or email info@enpg.com.
Or contact our Director of Business Development, Mitchell Karasik. Just send your building address and a contact name, and we’ll take care of the rest.
📧 mvkarasik@enpg.com
📞 914.263.1199
Starting the year informed is the simplest way to stay compliant, avoid surprises, and make smarter capital decisions as requirements continue to evolve.
