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Benchmarking Compliance

Energy Benchmarking Builds Actionable Insights

Energy benchmarking is more than just compliance—benchmarking data can increase visibility into performance, support budget planning, and inform upgrade prioritization for your national portfolios. Utility Benchmarking allows building owners, governments, and the public to better understand how their buildings use resources and plan for smarter and more cost-effective improvements.

Explore Required Jurisdictions

ENGIE Impact’s Energy Benchmarking Process

We manage monthly uploads of your energy and water data to ENERGY STAR® Portfolio Manager, perform data verification, and submit these reports to the jurisdiction website, ensuring benchmarking compliance across all required jurisdictions.

Our proven benchmarking method allows you to continuously manage your profile, keeping site data current and compliant.

Set up your ENERGY STAR® profile. Collect and configure site attributes in ENERGY STAR® Portfolio Manager for accurate, reliable scoring.
Benchmark monthly across your portfolio. Ongoing monthly data collection ensures a smooth, stress-free compliance season and maximizes ENERGY STAR® benefits portfolio-wide.
Identify compliance requirements. Each year, we align annual data with evolving regulations to clearly identify when and where reports are due—no guesswork, no surprises.
Submit reports and stay compliant. We validate your data and verify annually, then we submit to each required jurisdiction—ensuring full compliance, every time.

Streamline Energy Benchmarking and Utility Data Management

As your partner in utility expense management, we combine your energy benchmarking and utility data management, streamlining everything into just one strategic partner. Using our jurisdictional expertise, we cover your benchmarking so you can confidently comply with benchmarking regulations, gain portfolio-wide visibility, and build actionable roadmaps. ENGIE Impact is a proud partner of the Institute for Market Transformation (IMT).

Map Source: Building Energy Benchmarking & Transparency Policies Map | IMT

*This webpage is intended for informational purposes only and should not be relied upon or interpreted as legal advice for any purpose.

Canada

Vancouver, BC (Updated in 2026)

Name:

Energy and Carbon Reporting (Bylaw13472 Sec 2)

Covered Buildings:

Commercial: 50,000 sq ft or greater
Multifamily: 100,000 sq ft or greater

Compliance Requirements:

Whole Building Energy Benchmarking using ENERGY STAR Portfolio Manager
Data Verification Required: No

Compliance Timeline:

Deadline Commercial: June 1, Annual
Deadline Multifamily: June 1, Annual

Penalties:

Failure to comply with the by-law will render owners of buildings liable to penalties. The monetary amount is to be determined by regulation.

Montreal, QC

Name:

By-law concerning GHG emission disclosures and ratings of large buildings

Covered Buildings:

Commercial: 2,000 m² or greater
Multifamily: 25 or more units

Compliance Requirements:

Energy Benchmarking using ENERGY STAR Portfolio Manager
Data Verification Required: No

Compliance Timeline:

Deadline Commercial: June 30, Annual
Deadline Multifamily: June 30, Annual

Penalties:

The first offence is a fine of up to $1,000, the second offence is a fine of up to $2,000, and each additional offence is a fine of up to $4,000.

Ontario

Name:

Reporting of Energy Consumption and Water Use (Ontario Regulation 506/18)

Covered Buildings:

Commercial: 50,000 sq ft or greater
Multifamily: 50,000 sq ft or greater or 7 or more units

Compliance Requirements:

Energy and Water Benchmarking using ENERGY STAR Portfolio Manager
Data Verification Required: Yes

Compliance Timeline:

Deadline Commercial: July 1, Annually
Deadline Multifamily: July 1, Annually

Penalties:

Allows for administrative monetary penalties for failure to report and enforcement can include orders to comply and potential public disclosure of non-compliant buildings.

Toronto, ON

Name:

Energy and Water Reporting Bylaw

Covered Buildings:

All Buildings: 10,000 sq ft or greater

Compliance Requirements:

Energy and Water Benchmarking using ENERGY STAR Portfolio Manager
Data Verification Required: Yes

Compliance Timeline:

Buildings 4,645 square meters (50,000 square feet) and larger began reporting in July 1, 2024.
Buildings 929 to 4,644 square meters (10,000 to 49,999 square feet) will begin mandatory reporting in July 1, 2027.

Penalties:

Every person who contravenes any provision of this chapter, or a direction or order issued in accordance with this chapter, is guilty of an offence and on conviction is liable to a fine of no more than $100,000.

California

Statewide

Name:

Building Energy Benchmarking Program (AB802)

Covered Buildings:

Commercial: 50,000 sq ft or greater
Multifamily: 50,000 sq ft or greater or 17 or more active residential utility accounts

Compliance Requirements:

Whole Building Energy Benchmarking using ENERGY STAR Portfolio Manager
Data Verification Required: No

Compliance Timeline:

Deadline Commercial: June 1, Annual
Deadline Multifamily: June 1, Annual

Penalties:

The Commission has the authority to institute civil fines of up to $2,000 for non-compliance, after allowing a 30-day period to correct a violation.

Brisbane

Name:

Brisbane Building Efficiency Program (BBEP)

Covered Buildings:

Commercial: 10,000 sq ft or greater
Multifamily: 10,000 sq ft or greater

Compliance Requirements:

Whole Building Energy and Water Benchmarking using ENERGY STAR Portfolio Manager
Data Verification Required: No

Compliance Timeline:

Deadline Commercial: May 15, Annual
Deadline Multifamily: May 15, Annual

Penalties:

Penalties for non-compliance will be enforced as follows: (1) A fine not exceeding $100 for a first conviction; (2) A fine not exceeding $200 for a second conviction; (3) A fine not exceeding $500 for each additional conviction within 12 consecutive months.

Los Angeles

Name:

Existing Buildings Energy and Water Benchmarking Efficiency Program (EBEWE)

Covered Buildings:

Commercial: 20,000 sq ft or greater
Multifamily: 20,000 sq ft or greater

Compliance Requirements:

Whole Building Energy and Water Benchmarking using ENERGY STAR Portfolio Manager
Data Verification Required: No

Compliance Timeline:

Deadline Commercial: June 1, Annual
Deadline Multifamily: June 1, Annual

Penalties:

Failure to comply will result in a non-compliance fee of $202. This fee is subject to a 250% late charge/collection fee after 30 days, and after 60 days will be subject to a 12% interest accrual.

San Francisco

Name:

Existing Buildings Energy Ordinance

Covered Buildings:

Commercial: 10,000 sq ft or greater
Multifamily: 50,000 sq ft or greater

Compliance Requirements:

Whole Building Energy Benchmarking using ENERGY STAR Portfolio Manager
Data Verification Required: No

Compliance Timeline:

Deadline Commercial: May 1, Annual
Deadline Multifamily: May 1, Annual

Penalties:

Failure to submit a report for 30 days after the deadline will result in a written warning. If no report is filed within 45 days of written violation, then:

Buildings > 50,000 sq ft shall be fined up to $100 a day for up to 25 days in a year.
Buildings < 49,999 sq ft shall be fined up to $50 per day for up to 25 days in a year.

This does not apply to city-owned or municipal buildings.

West Hollywood (New in 2026)

Name:

Equitable Building Performance Standards (EBPS) - Benchmarking Requirements

Covered Buildings:

Commercial: 20,000 sq ft or greater
Multifamily: 20,000 sq ft or greater or 5 or more units

Compliance Requirements:

Whole Building Energy Benchmarking using ENERGY STAR Portfolio Manager
Data Verification Required: Yes

Compliance Timeline:

Deadline Commercial: May 15, Annual beginning in 2026
Deadline Multifamily: May 15, Annual beginning in 2026

Penalties:

The city may issue notices of violation for non-compliance. For each instance where an owner of a covered property fails to comply with benchmark reporting requirements, the Department may issue a citation and a fine not to exceed $1,000. If the City determines an owner has submitted an inaccurate report or if there is a discrepancy of more than 50% between third-party verified data and an owner's self-certified data, the owner will be cited and fined $1,000.

Berkeley

Name:

Building Energy Saving Ordinance (BESO Municipal Code 19.81)

Covered Buildings:

Commercial: 15,000 sq ft or greater
Multifamily: 15,000 sq ft or greater or 5 or more units, including congregant residences that house more than 16 occupants, such as cooperatives, fraternities, and sororities

Compliance Requirements:

Whole Building Energy Benchmarking using ENERGY STAR Portfolio Manager
Data Verification Required: No

Compliance Timeline:

Deadline Commercial: July 1, Annual
Deadline Multifamily: July 1, Annual

Penalties:

The instances for non-compliance will result in a fine of $100 per violation per day and may increase with subsequent citations to $200 per violation per day or $500 per violation per day. If sale occurs, fines are still attributed to owner they were levied against.

Chula Vista

Name:

Building Energy Saving Ordinance - Benchmarking Requirements

Covered Buildings:

Commercial: 20,000 sq ft or greater
Multifamily: 20,000 sq ft or greater

Compliance Requirements:

Whole Building Energy Benchmarking using ENERGY STAR Portfolio Manager
Data Verification Required: No

Compliance Timeline:

Deadline Commercial: May 20, Annual
Deadline Multifamily: May 20, Annual

Penalties:

Monetary fines may be levied on a per-incident basis, dependent on the size of the property out of compliance.

20,000-49,999 sq ft- up to $750 per incident.
50,000-99,999 sq ft - up to $1,500 per incident.
100,000+ sq ft - up to $2,250 per incident.

San Diego

Name:

Building Energy Benchmarking (Municipal Code Article 12, Division 1)

Covered Buildings:

Commercial: 50,000 sq ft or greater
Multifamily: 50,000 sq ft or greater or 17 or more residential utility accounts

Compliance Requirements:

Whole Building Energy Benchmarking using ENERGY STAR Portfolio Manager
Data Verification Required: No

Compliance Timeline:

Deadline Commercial: June 1, Annual
Deadline Multifamily: June 1, Annual

Penalties:

Failure to comply may be prosecuted as a misdemeanor, subject to a fine not more than $500 or imprisonment not exceeding 6 months, or both.

San Jose

Name:

Energy and Water Benchmarking Building Performance Ordinance

Covered Buildings:

Commercial: 20,000 sq ft or greater
Multifamily: 20,000 sq ft or greater

Compliance Requirements:

Whole Building Energy and Water Benchmarking using ENERGY STAR Portfolio Manager
Data Verification Required: No

Compliance Timeline:

Deadline Commercial: May 1, Annual
Deadline Multifamily: May 1, Annual

Penalties:

Buildings <50,000 sq ft may be fined $25 for each day of noncompliance, up to $2,500 per calendar year.
Buildings >50,000 sq ft may be fined $50 for each day of noncompliance, up to $5,000 per calendar year.

Colorado

Statewide (Updated in 2026)

Name:

Energy Performance for Buildings (HB 21-1286) - Benchmarking

Covered Buildings:

Commercial: 50,000 sq ft or greater
Multifamily: 50,000 sq ft or greater

Compliance Requirements:

Whole Building Energy Benchmarking using ENERGY STAR Portfolio Manager
Data Verification Required: No

Compliance Timeline:

Deadline Commercial: June 1, 2025. November 1 annually, starting in 2026 with 2025 benchmarking year data.
Deadline Multifamily: June 1, 2025. November 1 annually, starting in 2026 with 2025 benchmarking year data.

Penalties:

A building owner who fails to submit a benchmarking report, waiver request, or the corresponding fee ($100/building by June 1), will be considered non-compliant and subject to civil penalties of $500 for the first violation and $2,000 for each subsequent violation.

Boulder

Name:

Boulder Building Performance Ordinance

Covered Buildings:

Commercial: 20,000 sq ft or greater

Compliance Requirements:

Whole Building Energy Benchmarking using ENERGY STAR Portfolio Manager
Data Verification Required: No

Compliance Timeline:

Deadline Commercial: June 1, Annual

Penalties:

Non-compliance results in a civil penalty of $0.0025 per square foot per day, not to exceed $1,000 per day.

Fort Collins

Name:

Building Energy and Water Benchmarking Scoring Program

Covered Buildings:

Commercial: 5,000 sq ft or greater
Multifamily: 5,000 sq ft or greater

Compliance Requirements:

Whole Building Energy and Water Benchmarking using ENERGY STAR Portfolio Manager
Data Verification Required: No

Compliance Timeline:

Deadline Commercial: June1, Annual
Deadline Multifamily: June1, Annual

Penalties:

Failure to report will result in a notice of need to comply 30 days within the deadline. If failure to report continues, a notice of violation will be issued with a fine of $3,000 for each year of non-compliance.

Aspen

Name:

Building IQ - Benchmarking

Covered Buildings:

Commercial: 5,000 sq ft or greater
Multifamily: 15,000 sq ft or greater

Compliance Requirements:

Whole Building Energy and Water Benchmarking using ENERGY STAR Portfolio Manager
Data Verification Required: No

Compliance Timeline:

Deadline Commercial: June 1, Annual
Deadline Multifamily: June 1, Annual

Penalties:

$100 first offense, $200 second offense, court appearance and court set fines thereafter.

Denver

Name:

Energize Denver - Benchmarking

Covered Buildings:

Commercial: 25,000 sq ft or greater
Multifamily: 25,000 sq ft or greater

Compliance Requirements:

Whole Building Energy Benchmarking using ENERGY STAR Portfolio Manager
Data Verification Required: Yes

Compliance Timeline:

Deadline Commercial: June 1st
Deadline Multifamily: June 1st

Penalties:

$2,000 per year if benchmarking data is not submitted, data errors aren't fixed or reporting inaccurate information.

District of Columbia

Washington, DC (Updated in 2026)

Name:

Benchmarking Program

Covered Buildings:

Commercial: 10,000 sq ft or greater
Multifamily: 5 or more units

Compliance Requirements:

Whole Building Energy and Water Benchmarking using ENERGY STAR Portfolio Manager
Data Verification Required: Yes

Compliance Timeline:

Deadline Commercial: May 1, Annual
Deadline Multifamily: May 1, Annual

Penalties:

Failure to comply will result in a warning notice issued by the DOEE. Failure to provide updated data may lead to the issuance of a non-compliance penalty up to $100 per day of non-compliance.

Florida

Miami (Updated in 2026)

Name:

Building Efficiency 305 Benchmarking Program

Covered Buildings:

Commercial: 20,000 sq ft or greater
Multifamily: 20,000 sq ft or greater or 6 or more units

Compliance Requirements:

Whole Building Energy and Water Benchmarking using ENERGY STAR Portfolio Manager
Data Verification Required: No

Compliance Timeline:

Deadline Commercial: June 30, Annual
Deadline Multifamily: June 30, Annual

Penalties:

Failure to report benchmarking or reporting inaccurate benchmarking may result in a fine of $250 per day for a first-time offense or $500 per day for a repeat violation.

Orlando

Name:

Building Energy and Water Efficiency Strategy (BEWES)

Covered Buildings:

Commercial: 50,000 sq ft or greater
Multifamily: 50,000 sq ft or greater

Compliance Requirements:

Whole Building Energy and Water Benchmarking using ENERGY STAR Portfolio Manager
Data Verification Required: No

Compliance Timeline:

Deadline Commercial: May 1, Annual
Deadline Multifamily: May 1, Annual

Penalties:

Properties that fail to comply will be notified by the city and publicly listed as non-compliant.

Georgia

Atlanta

Name:

Commercial Building Energy Efficiency Ordinance

Covered Buildings:

Commercial: 25,000 sq ft or greater
Multifamily: 25,000 sq ft or greater

Compliance Requirements:

Whole Building Energy and Water Benchmarking using ENERGY STAR Portfolio Manager
Data Verification Required: No

Compliance Timeline:

Deadline Commercial: June 1, Annual
Deadline Multifamily: June 1, Annual

Penalties:

Failure to report will be noticed with a written warning (first violation); if not reported in the ensuing 30 days, a fine of $1000 is imposed. Each year of non-compliance is considered a separate violation.

Hawaii

Honolulu

Name:

Better Buildings Benchmarking

Covered Buildings:

Commercial: 25,000 sq ft or greater
Multifamily: 25,000 sq ft or greater

Compliance Requirements:

Whole Building Energy and Water Benchmarking using ENERGY STAR Portfolio Manager
Data Verification Required: No

Compliance Timeline:

Deadline Commercial: June 30, Annual
Deadline Multifamily: June 30, Annual

Penalties:

Fine up to $1,000 for failure to comply within the first 60 days of mailing of the notice of violation.
An additional $100 per day for each day the initial or updated benchmarking information is not reported to the department, with civil fines not to exceed $5,000 per facility per reporting year.

Illinois

Chicago

Name:

Chicago Energy Benchmarking Ordinance (Ordinance Section 18-14-101.5)

Covered Buildings:

Commercial: 50,000 sq ft or greater
Multifamily: 50,000 sq ft or greater

Compliance Requirements:

Whole Building Energy Benchmarking using ENERGY STAR Portfolio Manager
Data Verification Required: Yes

Compliance Timeline:

Deadline Commercial: June 1, Annual
Deadline Multifamily: June 1, Annual

Penalties:

A violation may be subject to a fine of up to $100 for the first violation and an additional fine up to $25 for each day the violation continues.

Oak Park

Name:

Climate Ready Oak Park

Covered Buildings:

Commercial: 10,000 sq ft or greater
Multifamily: 10,000 sq ft or greater or 4 or more units

Compliance Requirements:

Whole Building Energy and Water Benchmarking using ENERGY STAR Portfolio Manager
Data Verification Required: No

Compliance Timeline:

Deadline Commercial: December 31, Annual
Deadline Multifamily: December 31, Annual

Penalties:

Fine between $20 and $750 per day. Each day of non-compliance counts as a separate offence.

Evanston

Name:

Building Energy and Water Use Benchmarking Ordinance

Covered Buildings:

Commercial: 20,000 sq ft or greater
Multifamily: 20,000 sq ft or greater

Compliance Requirements:

Whole Building Energy and Water Benchmarking using ENERGY STAR Portfolio Manager
Data Verification Required: Yes

Compliance Timeline:

Deadline Commercial: June 30, Annual
Deadline Multifamily: June 30, Annual

Penalties:

$100 per month of non-compliance 20 days after written notice of violation.

Indiana

Indianapolis

Name:

Thriving Buildings Benchmarking (Bill 185-21)

Covered Buildings:

Commercial: 50,000 sq ft or greater
Multifamily: 50,000 sq ft or 4 or more units

Compliance Requirements:

Whole Building Energy and Water Benchmarking using ENERGY STAR Portfolio Manager
Data Verification Required: No

Compliance Timeline:

Deadline Commercial: June 1, Annual
Deadline Multifamily: June 1, Annual

Penalties:

Failure to make benchmarking submission first offence = $100
Failure to make benchmarking submission second offense = $250

Penalties for non-compliance do not take effect until January 1st, 2026.

Iowa

Des Moines

Name:

Energy and Water Benchmarking Ordinance (Ordinance 15.779)

Covered Buildings:

Commercial: 25,000 sq ft or greater
Multifamily: 25,000 sq ft or greater or 5 or more units

Compliance Requirements:

Energy and Water Benchmarking using ENERGY STAR Portfolio Manager
Data Verification Required: No

Compliance Timeline:

Deadline Commercial: July 1, Annual
Deadline Multifamily: July 1, Annual

Penalties:

The City of Des Moines will not be assessing any penalties for properties who are not in compliance with this ordinance.

Louisiana

New Orleans (New in 2026)

Name:

Building Energy Benchmarking

Covered Buildings:

Commercial: 20,000 sq ft or greater
Multifamily: 20,000 sq ft or greater

Compliance Requirements:

Energy Benchmarking using ENERGY STAR Portfolio Manager
Data Verification Required: No

Compliance Timeline:

Deadline Commercial: May 31, Annual
Deadline Multifamily: May 31, Annual
Properties with combined building area of 50,000 square feet and above must comply beginning January 1, 2026
Properties with combined building area of 20,000 square feet and above must comply beginning January 1, 2027

Penalties:

Failure to comply with the benchmarking requirement may result in fines between $1,000 and $3,000. Penalties will be waived in the first year a property is required to comply.

Maine

Portland

Name:

Energy Benchmarking (Section 6-217)

Covered Buildings:

Deadline Commercial: 20,000 sq ft or greater
Deadline Multifamily: 20,000 sq ft or 50 or more units

Compliance Requirements:

Energy and Water Benchmarking using ENERGY STAR Portfolio Manager
Data Verification Required: No

Compliance Timeline:

Deadline Commercial: May 1, Annual
Multi-tenant buildings are required to report once the utility is able to provide usage information in a convenient electronic format which is anticipated to be ready in early 2026 and that owners of multi-tenant buildings 20,000 square feet or more will be required to report in 2027.

Penalties:

The fines for non-compliance are $20 per day.

Maryland

Statewide

Name:

Benchmarking and Reporting [COMAR 26.28.02]

Covered Buildings:

Commercial: 35,000 sq ft or greater
Multifamily: 35,000 sq ft or greater

Compliance Requirements:

Energy Benchmarking using ENERGY STAR Portfolio Manager
Data Verification Required: Yes

Compliance Timeline:

Deadline Commercial: June 1, Annual
Deadline Multifamily: June 1, Annual

Penalties:

Up to $2,500 per violation under Maryland Environment Article §2-610. Each day of non-compliance may count as a separate violation, increasing liability. Not more than $50,000 total for any single administrative hearing.

Montgomery County

Name:

Building Energy Use Benchmarking (Bill 35-15)

Covered Buildings:

Commercial: 25,000 sq ft or greater
Multifamily: 25,000 sq ft or greater

Compliance Requirements:

Energy Benchmarking using ENERGY STAR Portfolio Manager
Data Verification Required: Yes

Compliance Timeline:

Deadline Commercial: June 1, Annual
Deadline Multifamily: June 1, Annual

Penalties:

Failure to report is considered a Class A Violation.
Class A civil violations are penalized with a $500 fine for the initial offense, and additional $750 fines for repeat offenses.

Massachusetts

Statewide

Name:

Large Building Energy Reporting (225 CMR 27.04)

Covered Buildings:

Commercial: 20,000 sq ft or greater
Multifamily: 20,000 sq ft or greater

Compliance Requirements:

Energy Benchmarking using ENERGY STAR Portfolio Manager
Data Verification Required: No

Compliance Timeline:

Deadline Commercial: June 30, Annual
Deadline Multifamily: June 30, Annual

Penalties:

If a distribution company or municipal utility fails to provide energy usage data for one or more covered buildings within 90 days of the issuance of a written notification, the Department may issue a fine of up to $150 per covered building per day of non-compliance. If a building owner fails to provide energy usage information within 30 days from the issuance of a written notification, the Department may issue a fine of up to $150 per day of non-compliance. If a lessee that comprises greater than 5% of the total gross floor area of a covered building fails to respond within 30 days to a written request for energy usage information by a building owner, the Department may issue a fine of up to $150 per day of non-compliance.

Cambridge

Name:

Building Energy Use Disclosure Ordinance (BEUDO)

Covered Buildings:

Commercial: 25,000 sq ft or greater
Multifamily: 50 or more units

Compliance Requirements:

Energy and Water Benchmarking using ENERGY STAR Portfolio Manager
Data Verification Required: Yes

Compliance Timeline:

Deadline Commercial: May 1, Annual
Deadline Multifamily: May 1, Annual

Penalties:

First violations will result in a written warning, and any subsequent violations carry a fine of up to $300 per day.

Lexington

Name:

Lexington Benchmarking

Covered Buildings:

Commercial: 25,000 sq ft or greater
Multifamily: 25,000 sq ft or greater

Compliance Requirements:

Energy and Water Benchmarking using ENERGY STAR Portfolio Manager
Data Verification Required: No

Compliance Timeline:

Deadline Commercial: May 15, Annual
Deadline Multifamily: May 15, Annual

Penalties:

$300 per violation.

Boston

Name:

Building Emissions Reduction and Disclosure (BERDO) Boston

Covered Buildings:

Commercial: 20,000 sq ft or greater
Multifamily: 20,000 sq ft or greater or 15 or more units, which take up more than 50 percent of building area including common space and hallways but excluding parking space

Compliance Requirements:

Energy and Water Benchmarking using ENERGY STAR Portfolio Manager
Data Verification Required: Yes

Compliance Timeline:

Deadline Commercial: May 15, Annual
Deadline Multifamily: May 15, Annual

Penalties:

Failure to report benchmarking within 30 days of notice shall be subject to:
a fine of $300 a day for non-residential buildings >35,000 sq ft or a parcel of buildings >100,000 sq ft and for residential buildings >35 units or 35,000 sq ft a fine of $150 a day for non-residential buildings >20,000 sq ft but <35,000 sq ft and residential buildings with >15 units or 35,000 sq ft
In the case the information is found to be inaccurate, the owner shall be subject to a fine between $1000 to $5000.
City buildings are exempt from penalties.

Chelsea

Name:

Building Emissions Reduction and Disclosure Ordinance (BERDO)

Covered Buildings:

Commercial: 20,000 sq ft or greater
Multifamily: 20,000 sq ft or greater or 20 or more units

Compliance Requirements:

Energy Benchmarking using ENERGY STAR Portfolio Manager
Data Verification Required: No

Compliance Timeline:

Deadline Commercial: June 30, Annual
Deadline Multifamily: June 30, Annual

Penalties:

Failure to report benchmarking requirements will result in a fine of $50 for the first offense, $150 for the second offense, $300 for the third offense, as enforced by building inspectors.

Newton (Updated in 2026)

Name:

Building Emissions Reduction and Disclosure Ordinance (BERDO) Newton – Benchmark

Covered Buildings:

Commercial: 20,000 sq ft or greater

Compliance Requirements:

Energy Benchmarking using ENERGY STAR Portfolio Manager
Data Verification Required: Yes

Compliance Timeline:

Deadline Commercial: September 15, Annual

Penalties:

Any violation of this ordinance shall be punishable by a fine of $300 per day for each day the violation continues.

Michigan

Ann Arbor

Name:

Energy & Water Benchmarking Ordinance

Covered Buildings:

Commercial: 20,000 sq ft or greater
Multifamily: 20,000 sq ft or greater

Compliance Requirements:

Energy and Water Benchmarking using ENERGY STAR Portfolio Manager
Data Verification Required: No

Compliance Timeline:

Deadline Commercial: June 1, Annual
Deadline Multifamily: June 1, Annual

Penalties:

Failure to report carries a maximum fine of $500 for the first offense, and a maximum fine of $1000 for each additional offense, plus the costs of prosecution.
Knowingly reporting false information carries a maximum fine of $500.

Detroit (Updated in 2026)

Name:

Energy Waste Reduction Benchmarking Ordinance

Covered Buildings:

Commercial: 25,000 sq ft or greater
Multifamily: 25,000 sq ft or greater

Compliance Requirements:

Energy and Water Benchmarking using ENERGY STAR Portfolio Manager
Data Verification Required: Yes

Compliance Timeline:

Deadline Commercial: June 1, Annual Deadline
Multifamily: June 1, Annual

Penalties:

Fines up to $10,000 per violation, with each day of non-compliance counting as a separate violation.

Minnesota

Statewide (Updated in 2026)

Name:

Building Energy Use Benchmarking Program (HF 2269)

Covered Buildings:

Commercial: 50,000 sq ft or greater
Multifamily: 50,000 sq ft or greater or 5 or more units

Compliance Requirements:

Energy Benchmarking using ENERGY STAR Portfolio Manager
Data Verification Required: No

Compliance Timeline:

Deadline Commercial: June 1, Annual
Deadline Multifamily: June 1, Annual

Penalties:

$1,000, may adjust with inflation.

Minneapolis

Name:

Energy Benchmarking, Benchmarking and Enforcement Timeline

Covered Buildings:

Commercial: 50,000 sq ft or greater
Multifamily: 50,000 sq ft or greater

Compliance Requirements:

Energy and Water Benchmarking using ENERGY STAR Portfolio Manager
Data Verification Required: No

Compliance Timeline:

Deadline Commercial: June 1, Annual
Deadline Multifamily: June 1, Annual

Penalties:

Information on penalties for non-compliance differs based on which source it comes from. Below are the penalties outlined in the municipal code.

Failure to benchmark shall result in a warning notice. Failure to comply within 45 days of written notice may be considered good cause for the denial, suspension, revocation, or refusal to issue a rental license, certificate of commercial building registration, or business license.

Edina

Name:

Efficient Building Ordinance

Covered Buildings:

Commercial: 25,000 sq ft to 49,999 sq ft
Multifamily: 25,000 sq ft to 49,999 sq ft

Compliance Requirements:

Energy and Water Benchmarking using ENERGY STAR Portfolio Manager
Data Verification Required: No

Compliance Timeline:

Deadline Commercial: June 1, Annual
Deadline Multifamily: June 1, Annual

Penalties:

Building owners will receive a written warning indicating why the building is noncompliant. The building owner has 45 business days to meet compliance, or the city has cause for the denial, suspension, revocation, or refusal to issue any applicable business license held by the property owner or person.

Missouri

Clayton (New in 2027)

Name:

Building Energy Awareness Ordinance

Covered Buildings:

Commercial: 100,000 sq ft or greater
Multifamily: 100,000 sq ft or greater

Compliance Requirements:

Energy and Water Benchmarking using ENERGY STAR Portfolio Manager
Data Verification Required: No

Compliance Timeline:

Deadline Commercial: April 1, 2027, and annually thereafter
Deadline Multifamily: April 1, 2027, and annually thereafter

Penalties:

Any violations of this ordinance shall result in a fine of not more than $1,000 or be punished by imprisonment in jail for no more than 90 days, or a punishment of both fine and imprisonment. Each day of violation counts as a separate offense.

St. Louis

Name:

Building Energy Awareness Ordinance

Covered Buildings:

Commercial: 50,000 sq ft or greater
Multifamily: 50,000 sq ft or greater

Compliance Requirements:

Energy and Water Benchmarking using ENERGY STAR Portfolio Manager
Data Verification Required: Yes

Compliance Timeline:

Deadline Commercial: May 1, Annual
Deadline Multifamily: May 1, Annual

Penalties:

Failure to comply shall result in a written warning. If benchmarking is not reported within 60 days of the issuance of written warning, it will be considered an offense and punishable via fine of not less than $50 but not more than $200. Each day of violation is considered a separate offense. No cumulative fine should exceed $1000 annually.

Kansas City

Name:

Kansas City Energy Empowerment Ordinance

Covered Buildings:

Commercial: 50,000 sq ft or greater
Multifamily: 50,000 sq ft or greater

Compliance Requirements:

Energy and Water Benchmarking using ENERGY STAR Portfolio Manager
Data Verification Required: No

Compliance Timeline:

Deadline Commercial: May 1, Annual
Deadline Multifamily: May 1, Annual

Penalties:

In the case of failure to report benchmarking, a written notice will be issued. If benchmarking information is not reported within 60 days of the written notice it will be a violation and will result in a fine, no less than $50 but not more than $500. For continued violation, each additional day will be considered a separate offense. Fines would not exceed $2,000 annually.

Nevada

Reno

Name:

Energy and Water Benchmarking Efficiency Ordinance (Section 14.30.014)

Covered Buildings:

Commercial: 30,000 sq ft or greater
Multifamily: 30,000 sq ft or greater

Compliance Requirements:

Energy and Water Benchmarking using ENERGY STAR Portfolio Manager
Data Verification Required: No

Compliance Timeline:

Deadline Commercial: April 1, Annual
Deadline Multifamily: April 1, Annual

Penalties:

Failure to report or submitting incomplete or inaccurate information will result in a written notice. Failure to correct within 30 days of written notice may result in notice of violation and penalty of up to $100. Failure to correct within 30 days of first violation may result in a second violation and penalty of $250. Failure to correct within 30 days of second violation may result in a fine of up to $500.

New Jersey

Statewide

Name:

CEA Benchmarking

Covered Buildings:

Commercial: 25,000 sq ft or greater
Multifamily: 25,000 sq ft or greater

Compliance Requirements:

Energy and Water Benchmarking using ENERGY STAR Portfolio Manager
Data Verification Required: No

Compliance Timeline:

Deadline Commercial: July 1, Annual
Deadline Multifamily: July 1, Annual

Penalties:

Compliance with benchmarking is considered prerequisite for participation in any of the NJ Board of Public Utility programs, as well as utility energy efficiency programs.

New York

Bedford

Name:

Building Health and Performance Law

Covered Buildings:

Multifamily: Two residential units or mixed-use commercial buildings containing at least one residential unit

Compliance Requirements:

Energy and Water Benchmarking using ENERGY STAR Portfolio Manager
Data Verification Required: No

Compliance Timeline:

Deadline Multifamily: The initial benchmarking shall occur no later than the required completion date as set by the Town of Bedford after registration of the Residential Rental Property, or 3 years after this Chapter is re-enacted, whichever comes first.

Penalties:

Maximum fee of $5,000, imprisonment not exceeding 6 months, or both fee and imprisonment. Each day a violation continues shall count as a separate offense.

New York

Name:

The NYC Benchmarking Law (LL84)

Covered Buildings:

Commercial: 25,000 sq ft or greater
Multifamily: 25,000 sq ft or greater

Compliance Requirements:

Energy and Water Benchmarking using ENERGY STAR Portfolio Manager
Data Verification Required: No

Compliance Timeline:

Deadline Commercial: May 1, Annual
Deadline Multifamily: May1, Annual

Penalties:

Failure to comply with benchmarking may result in a Notice of Violation by the Department; failure to submit by the June 30th deadline results in a penalty of $500. Continued failure to report by the next quarterly deadline may result in additional violations with penalties of $500 per violation, up to $2,000 a year.

If a correction of a violation occurs within 60 days of notice, no civil penalty shall be imposed.

Ohio

Columbus

Name:

Energy & Water Benchmarking and Transparency Ordinance (Ordinance 0452-2020)

Covered Buildings:

Commercial: 50,000 sq ft or greater
Multifamily: 50,000 sq ft or greater or 4 or more units

Compliance Requirements:

Energy and Water Benchmarking using ENERGY STAR Portfolio Manager
Data Verification Required: No

Compliance Timeline:

Deadline Commercial: June 1, Annual
Deadline Multifamily: June 1, Annual

Penalties:

If benchmarking is not reported within 30 days after the deadline, a written notice is issued. 60 days after a written notice, the owner will be subject to fees and penalties of up to $1,000 per day of non-compliance.

Oregon

Statewide (New in 2028)

Name:

Energy Performance Standards (HB3409) - Benchmarking

Covered Buildings:

Commercial: 20,000 sq ft or greater
Multifamily: 35,000 sq ft or greater

Compliance Requirements:

Energy Benchmarking using ENERGY STAR Portfolio Manager
Data Verification Required: No

Compliance Timeline:

Deadline Commercial: Tier 1 Buildings - June 1, Annual, Tier 2 Buildings - July 1, 2028, and each year after
Deadline Multifamily: Tier 1 Buildings - June 1, Annual
Tier 2 Buildings - July 1, 2028, and each year after

Penalties:

$5,000 plus continuing violation which may not exceed a daily amount of $1/yr/sf ft.

Portland

Name:

Commercial Building Energy Reporting (Ordinance No. 187095)

Covered Buildings:

Commercial: 20,000 sq ft or greater

Compliance Requirements:

Energy Benchmarking using ENERGY STAR Portfolio Manager
Data Verification Required: No

Compliance Timeline:

Deadline Commercial: April 22, Annual

Penalties:

Failure to report benchmarking requirements or reporting inaccurate information shall be subject to a written notice on first violation, and a civil penalty of up to $500 per 90-day period during which the violation continues.

Pennsylvania

Philadelphia

Name:

Building Energy Benchmarking (Bill No. 120428-A)

Covered Buildings:

Commercial: 50,000 sq ft or greater
Multifamily: 50,000 sq ft or greater

Compliance Requirements:

Energy and Water Benchmarking using ENERGY STAR Portfolio Manager
Data Verification Required: No

Compliance Timeline:

Deadline Commercial: June 30, Annual
Deadline Multifamily: June 30, Annual

Penalties:

Failure to report shall be subject to a fine of three hundred dollars $300 during the first 30 days following the compliance date.
Each day that the failure to comply following the initial 30 days shall constitute a separate violation, subject to a fine of $100 per day.

Pittsburgh

Name:

Pittsburgh Building Benchmarking Ordinance

Covered Buildings:

Commercial: 50,000 sq ft or greater

Compliance Requirements:

Energy and Water Benchmarking using ENERGY STAR Portfolio Manager
Data Verification Required: No

Compliance Timeline:

Deadline Commercial: June 1, Annual

Penalties:

Covered buildings that do not comply with benchmarking requirements will be publicly listed as being non-compliant on the city website.

Rhode Island

Providence (Updated in 2026)

Name:

Building Energy Reporting Ordinance

Covered Buildings:

Commercial: 20,000 sq ft or greater
Multifamily: 20,000 sq ft or greater or 15 or more units

Compliance Requirements:

Energy Benchmarking using ENERGY STAR Portfolio Manager
Data Verification Required: No

Compliance Timeline:

Deadline Commercial: May 15, Annual
Deadline Multifamily: May 15, Annual

Penalties:

First violation - written warning

Second and subsequent violation:

Covered properties >50,000 sq ft - $40 per day to a maximum of $4,000 per year.
Covered properties >20,000 sq ft - $30 per day to a maximum of $3,000 per year.

Texas

Austin

Name:

Energy Conservation and Disclosure Ordinance (ECAD)

Covered Buildings:

Commercial: 10,000 sq ft or greater
Multifamily: 10,000 sq ft or greater or 5 or more units

Compliance Requirements:

Energy Benchmarking using ENERGY STAR Portfolio Manager
Data Verification Required: No

Compliance Timeline:

Deadline Commercial: June 1, Annual
Deadline Multifamily: June 1, Annual

Penalties:

Non-compliance carries a fine up to $500. Acting with criminal negligence carries a fine up to $2,000.

Utah

Salt Lake City

Name:

Elevate Buildings (Municode CHAPTER 18.94)

Covered Buildings:

Commercial: 25,000 sq ft or greater

Compliance Requirements:

Energy Benchmarking using ENERGY STAR Portfolio Manager
Data Verification Required: No

Compliance Timeline:

Deadline Commercial: May 1, Annual

Penalties:

The Director may issue up to 3 written notices of noncompliance to the owner, allowing owner to cure such noncompliance within 90 days after each notice of violation. After the third written notice of violation, the Director may impose a fine of up to $500.00 per violation thereafter not exceeding a total of $1,000 annually.

Washington

Statewide (New in 2026)

Name:

Energy Benchmarking

Covered Buildings:

Commercial: 20,000 sq ft or greater
Multifamily: 20,000 sq ft or greater

Compliance Requirements:

Energy Benchmarking using ENERGY STAR Portfolio Manager
Data Verification Required: No

Compliance Timeline:

Commercial > 220,000 sq. ft. June 1, 2026.
Commercial 90,001 - 220,000 sq. ft. June 1, 2027.
Commercial 50,000 - 90,000 sq. ft. June 1, 2027.
Commercial 20,000 - 49,999 sq. ft. Multifamily > 20,000 sq. ft. June 1, 2031.

Penalties:

The building owner will be assessed the maximum penalty of $5000 plus a daily amount equal to $1.00 per square foot of gross floor area per year not to exceed a value greater than eighteen months of accrued penalty. Penalties are assessed for each compliance period.

For applicants that submit a noncompliance mitigation plan and who submit documentation demonstrating completion, daily penalties will be assessed from the scheduled compliance date to the date of approval of compliance or conditional compliance. The penalty will be assessed at an amount not to exceed 30% of $5000 plus a daily amount equal to $0.20 per square foot of gross floor area per year.

Seattle

Name:

Energy Benchmarking Law (Chapter 22.920)

Covered Buildings:

Commercial: 20,000 sq ft or greater
Multifamily: 20,000 sq ft or greater or Building owners shall comply with multi-family benchmarking standards when more than 50% of the gross building area, excluding parking, is used for multifamily benchmarking building uses

Compliance Requirements:

Energy Benchmarking using ENERGY STAR Portfolio Manager
Data Verification Required: Yes

Compliance Timeline:

Deadline Commercial: June 1, Annual
Deadline Multifamily: June 1, Annual

Penalties:

Noncompliance fines for reporting year will be streamlined into a single Notice of Violation issued 90 days after the June 1st reporting deadline in place of quarterly accruing fines. Fines for properties between 20,000 and 50,000 sq ft will be $2,000; Fines for properties greater than 50,000 sq ft will be $4,000.

Wisconsin

Madison (Updated in 2026)

Name:

Building Energy Savings Program

Covered Buildings:

Commercial: 25,000 sq ft or greater

Compliance Requirements:

Energy Benchmarking using ENERGY STAR Portfolio Manager
Data Verification Required: No

Compliance Timeline:

Deadline Commercial: June 30, Annual

Penalties:

$1,000 per 90 days of non-compliance.

Milwaukee (Updated in 2026)

Name:

Efficient Buildings Benchmarking Program

Covered Buildings:

Commercial: 50,000 sq ft or greater
Multifamily: 50,000 sq ft or greater

Compliance Requirements:

Energy Benchmarking using ENERGY STAR Portfolio Manager
Data Verification Required: No

Compliance Timeline:

Deadline Commercial: September 30, 2025, and June 30, annually after
Deadline Multifamily: June 30, 2026, and annually after

Penalties:

Failure to comply with the benchmarking requirements shall be subject to a fine of $1000 each 90 days of non-compliance.
Falsifying data will result in fines of $4,500 for the first violation, and $6,500 for each subsequent violation.

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Frequently Asked Questions

What Is Benchmarking Compliance?

Utility benchmarking is the practice of measuring how much energy and water a building consumes and comparing that against other, similar buildings. Utility benchmarking and transparency allows organizations to see how their buildings use energy and water. With this knowledge, they can make improvements to their buildings, comply with local laws and avoid fines, save money and cut waste, and support the local economy. Most available savings can be achieved with only low- or no-cost changes. Contact our experts to learn more.

What Is the Penalty for Noncompliance?

Energy benchmarking noncompliance can result in monetary fines and reputational damages. The severity of noncompliance penalties vary by location—see the map for details.

Why Is Energy Benchmarking Important?

In addition to remaining compliant with energy benchmarking requirements, benchmarking can help your organization identify inefficiencies, prioritize energy-saving investments, reduce operational costs, and track performance improvements over time. Energy benchmarking represents an opportunity to establish a data-driven baseline for gaining portfolio-wide visibility and building actionable roadmaps.

Who Can Complete Benchmarking for My Organization’s Buildings?

While building owners may complete energy benchmarking themselves, ENERGY STAR® is the golden standard for this service. And with ENGIE Impact as an expert partner, you can confidently comply with energy benchmarking regulations. Schedule a meeting with one of our experts to get started.