Local Law 133: Expanding Required Building List

Updated for 2025 — Local Law 133 (LL133) significantly expanded New York City’s benchmarking requirements by lowering the square footage threshold for compliance. As of 2020, LL133 requires buildings 25,000 square feet or larger to track and report their energy and water usage annually through the same system used for Local Law 84 (LL84).

This expansion added thousands of smaller buildings—many of them mid-size commercial, residential, or mixed-use properties—into the city’s long-term energy performance tracking program. For owners and managers of these newly covered buildings, LL133 is a critical part of staying compliant and eligible for energy incentives.

What Is Local Law 133?

Passed in 2016 and enacted in 2020, Local Law 133 amended Local Law 84 by lowering the benchmarking threshold from 50,000 to 25,000 square feet. The goal was to expand the city’s data on building energy use and extend sustainability efforts to a broader portion of the real estate market.

Covered buildings must measure annual energy and water consumption and submit this data through the EPA’s ENERGY STAR Portfolio Manager, the same tool used for LL84.

Who Must Comply with LL133?

LL133 applies to:

All individual buildings 25,000 square feet or larger in NYC
Two or more buildings on a single lot that together exceed 100,000 square feet
Condo and co-op associations whose combined floor area is 25,000 square feet or more

LL133 impacts commercial, residential, institutional, and mixed-use buildings across the five boroughs. It expanded LL84 to include thousands of mid-sized properties that were previously exempt.

Compliance Timeline for 2025

January 1 – April 30, 2025 – Collect utility data for the prior calendar year
May 1, 2025 (Extended in 2025) – Submit benchmarking report to the NYC Department of Buildings
June 30, 2025 – Grace period ends; fines begin for late filings
August 29, 2025 – Final extended deadline for owners who apply for a Local Law 97 extension

This timeline aligns with the broader LL84 benchmarking schedule. Reports must be submitted annually—even if no building systems or occupancy have changed.

Key Requirements of LL133

To remain compliant, building owners must:

Submit energy and water usage data
All utility data (electric, gas, steam, oil, water) for the prior year must be entered in ENERGY STAR Portfolio Manager.

Coordinate with tenants
Owners must request submetered or tenant-controlled energy data using the approved city form. Tenants must respond by February 15.

Ensure accurate building identification
Reports must include the correct Building Identification Number (BIN) and Borough-Block-Lot (BBL) data.

Maintain records
All benchmarking data must be retained for at least three years in case of audit.

Submit annually
Benchmarking is not a one-time requirement. Reports must be filed each year, even if there are no major system changes.

Why LL133 Matters

LL133 extended New York City’s energy performance tracking to thousands of additional buildings, helping:

Improve energy transparency in mid-sized buildings
Establish baselines for future upgrades and Local Law 97 emissions planning
Level the playing field for incentive eligibility and sustainability programs
Encourage benchmarking across the full commercial real estate market

Failure to comply may result in DOB violations and fines of $500 per quarter, up to a maximum of $2,000 annually. Properties may also become ineligible for energy incentive programs or ENERGY STAR certification.