Local Law 84: Benchmarking- Reporting Energy & Water Use

Updated for 2025 — New York City’s Local Law 84 (LL84) requires qualifying building owners to annually measure and report energy and water usage. As part of the city’s long-term sustainability goals, this process—known as benchmarking—is critical for tracking building performance and promoting energy efficiency across the five boroughs.

The 2025 LL84 deadline has been extended, but compliance remains mandatory. Here’s what property owners need to know.

What Is Benchmarking?

Benchmarking is the process of measuring a property’s resource consumption—such as electricity, gas, and water—over time and in comparison to similar buildings. The data is submitted through the EPA’s ENERGY STAR Portfolio Manager, a government-provided online tool.

As part of PlaNYC 2030, benchmarking results, including ENERGY STAR scores, are made publicly available. This transparency encourages building owners to invest in improvements and supports the city’s carbon reduction goals.

Who Must Comply with LL84?

Local Law 84 applies to:

Individual buildings in NYC that are 25,000 square feet or larger
Groups of buildings on a single tax lot that together total more than 100,000 square feet

Exemptions include:

Residential “garden apartment” properties that are three stories or less, where HVAC and hot water systems are owned and maintained by each individual unit owner

LL84 only applies to buildings located within the five boroughs of New York City.

Compliance Timeline for 2025

January 1 to April 30: Building owners must collect and enter utility data from the previous calendar year
May 1 (Extended in 2025): Final submission due to the NYC Department of Buildings
Late filings are subject to a fine of $500 per quarter, up to a maximum of $2,000 annually

Key Requirements of LL84

To remain compliant, building owners must:

Collect complete usage data
Include electricity, gas, oil, steam, and water usage for the full previous calendar year.

Request tenant energy usage
Use the official OLTPS (Mayor’s Office of Long-Term Planning and Sustainability) form to request data from tenants by January 1. Tenants must respond by February 15 or by their move-out date, whichever comes first.

Submit through ENERGY STAR Portfolio Manager
Create or update a building profile and submit benchmarking data through the official portal.

Use accurate property identifiers
Verify the correct Building Identification Number (BIN) and Borough, Block, Lot (BBL) information.

Maintain compliance records
Keep all benchmarking records for a minimum of three years in case of audit or DOB inquiry.

Submit to the DOB
Report must be submitted through the NYC Department of Buildings by the posted deadline.

Why Benchmarking Matters

Benchmarking offers visibility into operational performance and helps building owners and managers make informed capital planning decisions. It’s a performance management tool that helps building owners:

Evaluate the efficiency of core systems and infrastructure
Compare performance to peer buildings across NYC
Identify areas for cost-saving upgrades
Qualify for green programs, ENERGY STAR certifications, or financial incentives

Failure to comply may result in DOB violations being listed against the property and could make the building ineligible for energy performance incentives or ENERGY STAR recognition—both of which can impact leasing, refinancing, or long-term valuation.