The first compliance reports under New York City (NYC) Local Law 97 (LL97) were due May 1, 2025, and the New York City Department of Buildings (DOB) said it had nearly doubled its LL97 staff ahead of the deadline.
The NYC Comptroller’s “Cap the Credits” report projected, based on 2019 emissions data, that over 70% of covered buildings would exceed their2030 emissions limits. Given how many buildings are not on track for that threshold, total annual penalties across covered properties could prove substantial once stricter limits apply.
New reporting tools, penalty mitigation pathways, and expanded enforcement infrastructure have all developed since the law passed in 2019, changing how covered buildings manage both their obligations and their options.
Key Takeaways: NYC Local Law 97 compliance and recent regulatory changes
Building owners and property managers across New York City’s five boroughs face active enforcement of annual greenhouse gas emissions limits under Local Law 97. The following highlights key compliance requirements and recent regulatory developments affecting covered buildings.
What the law requires
- NYC Local Law 97 sets annual greenhouse gas emissions limits for buildings over 25,000 gross square feet
- Annual compliance reports, certified by a licensed Professional Engineer or Registered Architect, are due each May 1
- Excess emissions penalties of $268 per metric ton are assessed annually based on reported emissions that exceed the limit
What has changed recently
- The Building Energy Accountability and Monitoring (BEAM) portal launched in March 2025 as the official compliance submission system
- The Good Faith Effort (GFE) pathway, effective in January 2024, may allow noncompliant buildings to reduce or avoid penalties in 2024 and 2025, with the broader 2024-2029 compliance period subject to specific decarbonization-plan and progress requirements
- 2030 limits tighten significantly, with city analysis projecting that approximately 63% of covered buildings will exceed those limits without further action
Contact Rimkus to speak with a qualified Building Expert.
NYC Local Law 97 at a glance
LL97 sets annual greenhouse gas emissions limits for large buildings in New York City. Enacted in 2019 as part of the Climate Mobilization Act, it targets a 40% reduction by 2030 and an 80% reduction by 2050, in line with the city’s broader carbon-neutrality goal for 2050.
The law covers approximately 50,000 buildings exceeding 25,000 gross square feet (GSF), according to DOB.
Emissions limits vary by building use type and grow stricter across compliance periods. The first period (2024-2029) is designed to focus initial compliance pressure on buildings with the highest emissions intensity among covered properties. The second period (2030-2034) introduces limits that DOB estimates suggest could affect approximately 63% of large buildings if owners take no action.
For many buildings in that projected 63%, understanding current emissions relative to applicable limits is typically an early step, often supported by built environment services and baseline energy data.
Regulatory changes and enforcement updates (2024-2026)
The original penalty rates and emissions limits remain unchanged since 2019, but substantial implementing rules, reporting tools, and enforcement infrastructure have developed since 2024. Three developments stand out: a penalty mitigation pathway for noncompliant buildings, a dedicated reporting portal, and new rules addressing specific building categories.
These changes may matter because they may affect how owners document compliance, calculate exposure, and evaluate available mitigation pathways across the full 2024-2029 period. They also suggest that LL97 administration has moved from statutory requirements on paper to increasingly operational enforcement.
Good Faith Effort pathway
Under the 2024 LL97 implementing rules, a Good Faith Effort pathway may allow noncompliant buildings to reduce or avoid penalties during the 2024-2029 compliance period. Qualifying buildings are generally expected to maintain a current annual report and Local Law 88 compliance, and demonstrate at least one qualifying action. Accepted actions include a decarbonization plan, an approved permit application for work that will result in meeting emissions limits, or documentation of electrical service upgrades in progress.
One restriction applies to the decarbonization plan option: buildings that pursue this path under the GFE pathway may not use Renewable Energy Credits (RECs) during the 2024-2029 compliance period. Under the current DOB rules, owners generally need to choose between these two strategies.
BEAM reporting portal and enforcement staffing
DOB launched the BEAM portal in March 2025 as the official system for submitting LL97 compliance reports. DOB also significantly expanded its LL97 enforcement staff during 2024. Together, a dedicated portal and expanded review capacity suggest that compliance filings may be subject to more structured agency review than was typical in the initial rollout period.
Additional 2024-2026 developments
DOB and the NYC City Council took additional regulatory actions between 2024 and 2026:
- DOB adopted a third rules package in December 2024 that addressed affordable housing retrofits, financially constrained buildings, and other outstanding provisions
- The NYC City Council reinstated the J-51 Reform tax incentive program in December 2024, and the program may help rent-regulated buildings, co-ops, and condos finance upgrades that support LL97 compliance
- DOB published Bulletin 2025-014 in December 2025 to clarify emissions deductions for energy storage systems
- An appeals court ruling reinstated a lawsuit challenging LL97 on preemption grounds, though the law remains in full effect during litigation
DOB also updated the Covered Buildings List in March 2026 to reflect current records for all covered properties across the five boroughs.
The emissions reporting process
Annual emissions reporting involves multiple systems for payment, energy performance monitoring, and submission. Building owners first pay the filing fee in DOB NOW, which generates a confirmation number needed to unlock BEAM. They then populate ENERGY STAR Portfolio Manager (ESPM) with energy consumption data; BEAM applies fuel coefficients to calculate the building’s annual emissions.
Once BEAM produces a preliminary emissions total, eligible deductions may apply for clean energy resources, RECs (not capped during 2024-2029 under current LL97 rules), or carbon offsets (capped at 10% of emissions). LL97 then requires a licensed Professional Engineer (PE) or Registered Architect (RA) to certify the final report before submission.
That certified report must be filed by May 1 each year for the prior calendar year’s emissions, with a grace period to June 30 before late filing penalties apply; an extension to August 29 may be requested by June 30 for buildings that have engaged a registered design professional. Buildings without an approved extension that miss the June 30 grace period deadline face a late filing penalty of $0.50 per square foot per month.
Penalties and financial implications of noncompliance
The penalty rate for exceeding annual emissions limits is $268 per metric ton of CO₂ equivalent (tCO₂e) above a building’s cap. This penalty recurs annually and is assessed upon submission of a report showing excess emissions. A Building Owners and Managers Association (BOMA) brief warned that large noncompliant buildings could face steep fines, and a Citizens Budget Commission report the NYC Comptroller calculated the average annual penalty for noncompliant commercial buildings at $1.86 per square foot.
Additional penalties apply for other violations:
- Failure to file an annual report incurs a penalty of $0.50 per square foot per month after the May 1 deadline
- False statements can result in civil penalties of up to $500,000, imprisonment of up to 30 days, or both
These penalty structures apply regardless of GFE status. Because each year of noncompliance adds to the cumulative exposure, comparing projected retrofit costs against ongoing fine obligations is often central to compliance planning decisions.
The Comptroller’s analysis, citing Urban Green Council estimates, places the average retrofit cost at approximately $9.80 per square foot for the 2030 compliance period, a one-time capital expenditure compared to the $1.86 per square foot annual fine exposure for the average commercial building, according to the NYC Comptroller’s Cap the Credits report.
Several financial incentives may help offset these costs, including the J-51R abatement, federal Inflation Reduction Act (IRA) tax credits, and NYC Commercial Property Assessed Clean Energy (C-PACE) financing.
How compliance typically works in practice
Many buildings reduce emissions through a combination of energy auditing, building system upgrades, and performance monitoring. The most common strategies depend on building type, age, and current energy profile.
- Heating, ventilation, and air conditioning (HVAC) system upgrades and electrification, often considered the highest-impact measure for commercial buildings
- Building envelope improvements, including window replacement and insulation upgrades
- Light-emitting diode (LED) lighting with controls (also independently required under Local Law 88)
- Retro-commissioning, which optimizes existing systems without capital replacement
- On-site renewable energy, such as rooftop solar
The appropriate mix of these measures depends on a building’s current emissions profile, system age, and available capital, making early assessment a practical first step for owners planning ahead of the 2030 compliance period.
Why early planning for 2030 limits may matter
Active enforcement, accumulating annual penalties, and stricter limits ahead for most covered buildings suggest that earlier planning may support lower-cost compliance options. The earlier planning begins, the broader the range of strategies that may remain available before 2030 limits take effect.
Early engagement with qualified energy and building systems professionals may help clarify compliance gaps and inform capital planning decisions. Among the most useful early steps, assessment and advisory services may help establish a clear picture of current system performance against compliance targets and identify the most viable path forward.
Preparing for the 2030 compliance period
LL97 administration has shifted increasingly toward active operational enforcement since the statutory framework took effect in 2019. Contact Rimkus to connect with a qualified Building Expert on NYC Local Law 97 compliance.
Frequently asked questions
What qualifies a building for the Good Faith Effort pathway?
Qualifying actions include active retrofit work, a decarbonization plan, or an approved permit application for work that will result in meeting emissions limits. Buildings using a decarbonization plan may not use RECs during the 2024-2029 compliance period under current DOB rules.
What is the difference between LL97 and LL84?
Local Law 84 requires covered buildings to annually benchmark and report energy and water consumption data, establishing a transparency framework for building performance. Local Law 97 builds on that data by setting enforceable greenhouse gas emissions limits with financial penalties for noncompliance, moving from disclosure to mandated reduction.
Which buildings are covered by NYC Local Law 97?
Local Law 97 covers most privately owned buildings over 25,000 gross square feet in New York City, as well as two or more buildings on the same tax lot that together exceed 50,000 square feet, and condominium buildings under the same board of managers that together exceed 50,000 square feet. The NYC Department of Buildings publishes an annually updated Covered Buildings List (CBL) that building owners can use to confirm their compliance status. Certain affordable housing buildings and houses of worship follow a separate compliance pathway under Article 321.
Authored by: Rimkus Built Environment Solutions Marketing Team
Published April 10, 2026.
This article is intended to provide general information and insights into prevailing industry practices. It is not intended to constitute, and should not be relied upon as, legal, technical, or professional advice. The content does not replace consultation with a qualified expert or professional regarding the specific facts and circumstances of any particular matter.