What Local Law 84 requires
Local Law 84 of 2009, as amended by Local Law 133 of 2016, is New York City's energy and water benchmarking law. Owners of covered buildings have to measure the building's whole-building energy use (and water use, where the city requires it) for each calendar year and report it to the city through the EPA's ENERGY STAR Portfolio Manager by May 1 of the following year. The data feeds the building's energy grade under Local Law 33/95 and the carbon emissions calculations under Local Law 97.
A building is covered if it appears on the city's annual Covered Buildings List. In general that means any single building over 25,000 gross square feet, two or more buildings on the same tax lot totaling more than 100,000 gross square feet, two or more condominium buildings under the same board totaling more than 100,000 gross square feet, and city-owned buildings above the threshold. One- to three-family homes are exempt. The Covered Buildings List is published each year, and buildings on it must benchmark the prior calendar year's data even if the owner believes the building should not be listed; disputes are handled separately.
Deadlines and penalties
The annual deadline is May 1. For the 2026 cycle, that means 2025 calendar-year data was due May 1, 2026. Buildings that miss it are subject to a $500 penalty each quarter the report remains outstanding (May 1, August 1, November 1 and February 1), up to $2,000 per year, and the violation is repeated every year until a compliant report is accepted. The city asks that the Portfolio Manager property be shared with the Department of Buildings at least 15 business days before the deadline so the submission can be reviewed and corrected if it is rejected.
Why submissions get rejected
Most rejected LL84 submissions share the same causes: the BBL or BIN is missing or formatted incorrectly; the gross floor area or property use breakdown does not match city records; the energy data does not cover a full 12 months; tenant electric meters or a second fuel are missing, so the building is under-reported; water data is missing where the list marks it as required; or the property was shared with the city too late to fix any of the above. A rejected submission is treated as a missed submission for penalty purposes.
What our LL84 benchmarking service includes
- Confirming whether the building is on the current Covered Buildings List and, if it is listed in error, preparing the exemption request
- Setting up or cleaning up the ENERGY STAR Portfolio Manager property, including correct BBL, BIN, gross floor area and use types
- Collecting 12 months of whole-building energy data: Con Edison and National Grid account data, aggregate tenant data requests for multi-tenant buildings, fuel oil deliveries and steam
- Entering water data from DEP where required
- Quality-checking the entry against the building's prior submissions and city records before sharing
- Sharing the property with the city and submitting the report before the May 1 deadline
- Responding to DOB rejection notices and resubmitting
- Disputing LL84 violations issued in error through DOB NOW
- Coordinating the annual Local Law 33/95 energy grade posting near the building entrance
- Flagging Local Law 87 audit and retro-commissioning due dates and Local Law 97 emissions reporting obligations that follow from the same data
How LL84 connects to LL97, LL87 and LL33
The benchmarking report is the base record for the rest of the city's building energy laws. Local Law 33/95 turns the Portfolio Manager score into a letter grade that must be posted at the building. Local Law 87 requires an energy audit and retro-commissioning every ten years for buildings over 50,000 square feet. Local Law 97 sets carbon emissions limits for buildings over 25,000 square feet, with the first compliance period starting in 2024 and annual emissions reports due each May 1, and its penalties are calculated from the same energy data. An accurate LL84 record is the difference between a manageable LL97 position and an expensive surprise.
Who this is for
Owners and managers of multifamily, mixed-use and commercial buildings over 25,000 square feet, co-op and condo boards, and property managers responsible for portfolios that include covered buildings. We work across all five boroughs and can take over a building that has missed one or more years and bring it current.