Local Law 84 Benchmarking Deadline: May 1, 2026

Local Law 84 is NYC’s annual “energy and water report card.” Covered buildings must measure energy and water use every year using the U.S. EPA’s ENERGY STAR Portfolio Manager and submit that data to NYC by May 1.

The NYC Department of Buildings explains that the annual benchmarking data is due May 1 each year, and the report is submitted through ENERGY STAR Portfolio Manager. (NYC Department of Buildings — Benchmarking)

Think of benchmarking as a reporting obligation — not a promise that your building hits a certain efficiency score.

Whether a building must comply depends on the City’s “Covered Buildings List” criteria. In practice, owners often get surprised when:

• A mixed-use property’s square footage pushes it over the threshold
• A condo has multiple buildings on one lot and the combined size triggers coverage
• Ownership or building records are outdated and don’t match how the property is actually used

If you’re unsure, start by checking your building’s status and instructions on DOB’s benchmarking page. (NYC Department of Buildings — Benchmarking)

The “hard” deadline is May 1, 2026, but enforcement follows a quarterly schedule.

DOB states that if you do not submit by May 1, you can aim for the next quarterly deadline of August 1, followed by November 1 and February 1 (of the following year). (NYC Department of Buildings — Benchmarking)

DOB’s Local Law 84 violations page repeats the same quarterly schedule and explains that penalties can be issued quarterly until you submit. (NYC Department of Buildings — LL84 Benchmarking Violations)

Pull quote: If you miss May 1, you’re not “done for the year” — you’re on the clock for quarterly penalties until you file.

Quick penalty summary (typical scenario)

DOB explains that failing to submit by May 1 can result in a $500 penalty, and continued failure to submit by quarterly deadlines can result in additional penalties up to $2,000 per year. (NYC Department of Buildings — Benchmarking)

Deadline you miss	Typical penalty outcome (Local Law 84)
May 1	$500 violation issued for non-compliance
August 1	Another $500 possible if still not filed
November 1	Another $500 possible if still not filed
February 1 (next year)	Another $500 possible if still not filed (up to $2,000/year)

Use this checklist as your internal “close process” for benchmarking.

A. Confirm the filing method you’ll use

Local Law 84 reporting runs through ENERGY STAR Portfolio Manager, but the City’s portals and labels can involve other steps.

• Make sure you have access to the building’s ENERGY STAR Portfolio Manager profile
• Confirm who will submit: owner, property manager, or a consultant

DOB also operates multiple compliance modules through DOB NOW, which is the agency’s online filing system for owners and filing representatives. (NYC Department of Buildings — Using DOB NOW)

B. Gather the data that usually delays owners

Start early because utility data and tenant information can take time.

• Electric usage (whole-building data if applicable)
• Gas usage (if separately metered, you may need aggregation)
• Water and sewer usage
• Accurate gross square footage and primary uses (residential, retail, community facility, etc.)

C. Build and QA the Portfolio Manager entry

Before you submit:

• Confirm the reporting year (the May 1, 2026 deadline is typically for the prior calendar year’s data)
• Check that meters cover the full property, not just a portion
• Fix obvious outliers (for example, a meter that shows zero usage for multiple months)

D. Submit and keep proof

After a successful submission:

• Save the confirmation or submission receipt
• Keep a PDF or screenshot of the final report
• Document who submitted and when

Owners sometimes submit but still receive a notice because the report is not “fully compliant.” The most common triggers:

• Missing required fields in Portfolio Manager
• Incorrect property type or use breakdown
• Meters not connected to the property correctly
• Data that fails validation (for example, months missing)

If you receive a violation you believe is incorrect, DOB provides a process to challenge benchmarking violations. (NYC Department of Buildings — Benchmarking)

Benchmarking is not isolated. It often ties into other annual and multi-year obligations, including sustainability reporting and planning for upgrades.

If you’re already preparing for broader energy compliance, see:

• NYC Local Law 97/84 May 2026 Deadline
• NYC compliance checklist for small-building owners

If you’re managing other DOB-driven requirements, these may help:

• Local Law 152 gas piping inspection deadline