Updated for 2025 — Local Law 88 (LL88) is a key part of New York City’s Greener, Greater Buildings Plan. It mandates two primary upgrades for qualifying buildings:
- Installation of energy-efficient lighting systems in non-residential spaces
- Installation of tenant sub-meters to measure individual electrical usage
Both requirements aim to reduce energy consumption and increase transparency in commercial buildings.
The deadline for compliance has been extended, but property owners should act now to avoid last-minute upgrades and potential compliance issues.
What Is Local Law 88?
Passed in 2009 and expanded under subsequent local energy laws, LL88 requires property owners to upgrade lighting and electrical systems in large commercial and mixed-use buildings. Its goal is to modernize building infrastructure and support NYC’s long-term carbon reduction targets.
LL88 has two main provisions:
- Sub-metering: Commercial tenants must have separate electric meters to track their own energy usage
- Lighting upgrades: All common areas and tenant spaces must meet the latest NYC Energy Conservation Code (NYCECC) standards
Who Must Comply with LL88?
LL88 applies to:
- Buildings over 50,000 gross square feet
- Two or more buildings on a single lot that together exceed 100,000 gross square feet
- Condo associations with more than 100,000 gross square feet of total unit area
This includes most office towers, large mixed-use buildings, and commercial properties.
Compliance Timeline for 2025
- January 1 – December 31, 2025: Final window to implement lighting upgrades and install sub-meters
- The previous compliance deadline has been extended, but no further extensions are expected
Key Requirements of LL88
To comply with Local Law 88, building owners must:
Upgrade non-compliant lighting systems
All lighting in hallways, stairwells, mechanical rooms, lobbies, tenant spaces, and other non-residential areas must meet the NYCECC standards in effect at the time of retrofit.
Install tenant sub-meters
Tenants in covered buildings must have dedicated meters that track electric usage. This applies to commercial tenants only—residential units are not required to sub-meter.
Provide monthly electricity statements
Once sub-meters are installed, tenants must receive monthly usage breakdowns, either via physical mail or digital delivery.
File a report with the DOB
By the deadline, property owners must submit documentation certifying that lighting upgrades and sub-metering have been completed or are otherwise exempt.
Why LL88 Matters
LL88 plays a major role in helping NYC reach its building emissions reduction goals under Local Law 97. By requiring owners and tenants to monitor usage more closely, LL88:
- Encourages smarter energy consumption
- Promotes upgrades to efficient LED and smart lighting systems
- Prepares buildings for participation in energy conservation programs
- Enhances transparency for commercial tenants
Non-compliance can result in DOB violations and disqualification from incentive programs or energy certifications, including ENERGY STAR.
How Benchmarking.NYC Can Help
Benchmarking.NYC offers full LL88 compliance support, including:
- Lighting system assessments
- Contractor coordination and upgrade planning
- Sub-metering strategy for tenant spaces
- DOB filing and documentation assistance
We work with building owners and property managers to ensure upgrades are code-compliant, efficient, and filed before the final deadline.
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