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Reference table · checked September 26, 2026

Commercial building performance standards: the US laws that put HVAC work on a deadline

Published by B2B Lead Growth · Last updated: September 26, 2026

A building performance standard is a law that makes existing commercial buildings meet an energy or emissions target by a set date. The table below lists 14 US laws we verified on each jurisdiction’s own official page on September 26, 2026.

For a commercial HVAC contractor these laws matter for one reason: they give a building owner a dated reason to plan work on the heating, cooling and controls — an operations and maintenance program, an energy audit, a retro-commissioning study, a replacement. That makes a covered building worth knowing about. It does not make it a building with a problem, and the section below says so before the table does.

What this table does not prove

A law is a reason for an owner to plan, and a reason for you to introduce yourself. It is never a finding about a building. Read every row with these limits.
  • It does not show that any building is out of compliance. Covered is not failing.
  • It does not show that a building's HVAC equipment needs work, or what work. Only the owner and their engineer can say that.
  • It does not show that anyone is buying. A deadline is the owner's obligation, not a request for proposals.
  • It is not complete. It lists only the laws we could verify on an official page on the check date. Other cities, counties and states have their own.
  • It leaves out most exemptions, extensions and alternative ways to comply. Every law listed has some.
  • It is not legal advice. Laws and deadlines change; open the official source before you rely on a row.

US building performance and benchmarking laws, checked September 26, 2026

  • Jurisdiction and law
    New York CityLocal Law 97 of 2019 (Administrative Code §28-320)
    Who it covers
    With some exceptions, buildings over 25,000 gross square feet, two or more buildings on one tax lot that together exceed 50,000, and condominium buildings under one board that together exceed 50,000.
    What it requires
    Annual greenhouse gas emissions limits, and an annual report showing whether the building met its limit for the previous year.
    Key dates
    Limits apply from 2024 and get stricter over time, toward a 40% cut in covered buildings' emissions by 2030 and net zero by 2050. The first reports, for 2024, were due December 31, 2025. Reports for 2025 are due May 1, 2026, with a grace period to June 30.
  • Jurisdiction and law
    Boston, MassachusettsBuilding Emissions Reduction and Disclosure Ordinance (BERDO)
    Who it covers
    Nonresidential buildings of 20,000 square feet or more, multifamily buildings with 15 or more units, and tax parcels whose buildings add up to either.
    What it requires
    Annual energy and water reporting, verified by a qualified third party in the first year and every five years after, and annual emissions limits that fall over time toward net zero by 2050. The city publishes a covered buildings list.
    Key dates
    Reports are due May 15 each year. Emissions limits start in 2025 or 2030, depending on the building's size.
    Official source
    City of Boston — BERDOChecked 2026-09-26
  • Jurisdiction and law
    Cambridge, MassachusettsBuilding Energy Use Disclosure Ordinance (BEUDO), as amended June 2023
    Who it covers
    Energy and water reporting from commercial properties over 25,000 square feet and multifamily properties over 50 units.
    What it requires
    Nonresidential buildings must reduce their greenhouse gas emissions to net zero.
    Key dates
    Net zero by 2035 for nonresidential buildings over 100,000 square feet, and by 2050 for smaller ones.
    Official source
    City of Cambridge — news release, June 2023Checked 2026-09-26
  • Jurisdiction and law
    Washington, DCBuilding Energy Performance Standards (BEPS), Title III of the Clean Energy DC Omnibus Act of 2018, and the District's energy benchmarking law
    Who it covers
    Benchmarking: every building over 10,000 square feet. The pages we checked do not state the standard's own size thresholds.
    What it requires
    Annual energy and water benchmarking, reported to DOEE and published on its building performance map, and a building energy performance standard. DOEE states the program's aim as cutting greenhouse gas emissions and energy use 50% by 2032.
    Key dates
    Benchmarking reports are due May 1 each year. The next third-party verification is due in 2027, for 2026 data.
  • Jurisdiction and law
    Maryland (statewide)Building Energy Performance Standards (BEPS)
    Who it covers
    Commercial and multifamily buildings of 35,000 square feet or more. Exemption categories include hospitals, K-12 schools, manufacturing, agricultural, federally owned and individually designated historic buildings.
    What it requires
    An annual benchmarking report, and building improvements over time to meet performance standards in the 2030s.
    Key dates
    For 2026, benchmarking reports submitted by June 30, 2026 were accepted as on time, under a department extension.
    Official source
    Maryland Department of the Environment — BEPSChecked 2026-09-26
  • Jurisdiction and law
    Montgomery County, MarylandBuilding Energy Performance Standards (BEPS)
    Who it covers
    Most buildings of 25,000 square feet or more, including new buildings once they are in use.
    What it requires
    Meet an energy use intensity standard by set deadlines, or file a building performance improvement plan prepared by a credentialed energy auditor, plus annual benchmarking.
    Key dates
    Benchmarking reports are due June 1. The first groups' interim standard is judged on 2028 energy use (deadline December 31, 2028).
  • Jurisdiction and law
    Colorado (statewide)Building Performance Colorado (HB21-1286)
    Who it covers
    Most commercial buildings of 50,000 square feet or more.
    What it requires
    Annual energy benchmarking, and building performance standards that support the state's goals of cutting emissions from commercial buildings 7% by 2026 and 20% by 2030, compared with 2021.
    Key dates
    The 2026 reporting window runs July 1 to November 1. Owners can change their 2030 compliance path without documentation until November 1, 2028.
  • Jurisdiction and law
    Denver, ColoradoEnergize Denver Building Performance Policy
    Who it covers
    Commercial and multifamily buildings of 5,000 square feet or more, with separate requirements for 5,000–24,999 square feet and for 25,000 and up.
    What it requires
    An energy efficiency requirement, with benchmarking and building energy use targets set out in the city's rules. The city says it is not a requirement to electrify heating or cooling, and not a mandate to replace HVAC equipment before the end of its useful life.
    Key dates
    Ordinance passed 2021. The current rules took effect August 27, 2026. The pages we checked do not list the target years.
  • Jurisdiction and law
    St. Louis, MissouriBuilding Energy Performance Standard (Ordinance 71132)
    Who it covers
    Almost all commercial, multifamily, institutional and municipal buildings of 50,000 square feet or more.
    What it requires
    An annual benchmarking report and a site energy use intensity target set by the Building Energy Improvement Board. Missing a target can bring fines of up to $1,000 a year.
    Key dates
    Ordinance effective June 4, 2020. Most buildings had until May 2025 to meet the first standard, which is reviewed every four years.
  • Jurisdiction and law
    Washington StateClean Buildings Performance Standard (CBPS)
    Who it covers
    Tier 1: buildings whose nonresidential, hotel, motel and dormitory floor area exceeds 50,000 square feet. Tier 2: buildings of 20,001–50,000 square feet, and multifamily buildings over 20,000.
    What it requires
    Tier 1: benchmark energy use, develop and implement an operations and maintenance (O&M) program and an energy management plan, and meet an energy performance metric.
    Key dates
    Tier 1 reports due June 1, 2026 (over 220,000 sq ft), June 1, 2027 (90,001–220,000) and June 1, 2028 (50,001–90,000). Tier 2 reports due July 1, 2027.
  • Jurisdiction and law
    Oregon (statewide)Oregon Building Performance Standard (House Bill 3409, 2023)
    Who it covers
    Tier 1: nonresidential, hotel and motel buildings of 35,000 square feet or more. Tier 2: those of 20,000–35,000 square feet, and multifamily, hospital, school, university, dormitory and similar buildings of 35,000 or more.
    What it requires
    Both tiers: an energy use intensity from 12 months of bills, against a target. Tier 1 also: an operations and maintenance plan and an energy management plan; a Tier 1 building expecting to miss its target needs an energy audit, a life-cycle cost assessment and cost-effective efficiency measures.
    Key dates
    Tier 1: June 1, 2028 (200,000 sq ft and up), June 1, 2029 (90,000–200,000), June 1, 2030 (35,000–90,000). Tier 2: July 1, 2028.
  • Jurisdiction and law
    Seattle, WashingtonBuilding Emissions Performance Standard (BEPS)
    Who it covers
    Nonresidential and multifamily buildings larger than 20,000 square feet.
    What it requires
    Benchmarking verification by a qualified person, a greenhouse gas report with the owner's plan to comply, then emissions targets that tighten to net zero.
    Key dates
    Verification and the report are due 2027–2030, depending on size. Initial targets apply 2031–2035; net zero by 2041–2050.
  • Jurisdiction and law
    Los Angeles, CaliforniaExisting Buildings Energy & Water Efficiency Program (EBEWE), Municipal Code Division 97
    Who it covers
    Privately owned buildings of 20,000 square feet or more. City-owned buildings have their own thresholds.
    What it requires
    Energy and water benchmarking by June 1 every year, for the calendar year before, and an energy and water audit with retro-commissioning (A/RCx) once every five years.
    Key dates
    A/RCx is due December 1 of the building's compliance year, set by the last digit of its LADBS building ID: next due December 1, 2026 for IDs ending in 0 or 1, and December 1, 2027 for 2 or 3.
  • Jurisdiction and law
    Chicago, IllinoisChicago Energy Benchmarking Ordinance (benchmarking only)
    Who it covers
    Buildings of 50,000 square feet and above that meet the ordinance's criteria.
    What it requires
    Report energy use every year and verify the data every three years. The city's page describes reporting and verification only — no performance target. The city publishes a covered buildings list.
    Key dates
    Reports are due June 1 each year.
    Official source
    City of Chicago — Chicago Energy BenchmarkingChecked 2026-09-26

Every row was read on the official page it links, on September 26, 2026, and says only what that page says. Where a page did not state something — Washington, DC’s size thresholds for its standard, Denver’s target years — the row says so rather than filling the gap from a summary. For jurisdictions not listed here, the Institute for Market Transformation keeps a map of US building benchmarking and performance policies, which ENERGY STAR points to. Found an error? Write to nishanth@b2bleadgrowth.com and we will correct the row and its date.

Where commercial HVAC work comes into these laws

None of the official pages we read requires a building to buy a particular piece of equipment. What the laws ask for falls into four kinds, and the official pages say plainly where heating and cooling come in:

  • A written operations and maintenance program. Washington’s Tier 1 buildings must develop and implement an O&M program and an energy management plan, and Oregon’s Tier 1 buildings must file an O&M plan and an energy management plan. Scheduled maintenance is the work a commercial HVAC maintenance agreement delivers.
  • Energy audits and retro-commissioning. Los Angeles requires an audit and retro-commissioning of every covered building once every five years. Oregon requires an energy audit and a life-cycle cost assessment from a Tier 1 building that expects to miss its target, and Montgomery County’s improvement-plan path needs a credentialed energy auditor.
  • Energy or emissions targets. New York City’s Department of Buildings says covered buildings will need energy efficiency retrofits and better building operations to meet their limits. Seattle says most of its building emissions come from burning fossil fuels for space and water heating. One of Washington’s compliance paths is replacing fossil-fuel space conditioning equipment with electric heat pumps. Denver, by contrast, says its policy is not a mandate to replace HVAC equipment before the end of its useful life.
  • Benchmarking only. Chicago’s ordinance asks for reporting and verification, not a target. It creates no work by itself, but it produces a public, dated record of the building.

How an owner meets a target is the owner’s decision, made with their engineer. That is also where this service stops: we find the account and start the conversation; the assessment, the scope and the price are the contractor’s.

How to mention a law without diagnosing a building

Write about the law as the reason you are getting in touch, stated as a fact the owner can check. Never write that the building fails it, is behind on it, or needs work because of it. You have not seen the building.

An opening line that holds up: “I saw [building name] on [city]’s published list of buildings covered by [law name], with the next report due [date from the official source].” Every bracket is a fact you checked, and several of the agencies above — Boston and Chicago among them — publish one. The one that does not: “Your building is going to miss its target.” That is a guess about a building, and the reader knows it.

A law is one kind of commercial HVAC prospecting trigger, with the same rule: a reason to contact an account, never proof of need. The owner is the usual reader for a compliance deadline — building owner outreach covers when to write to the owner and when to write to the manager — and an in-house team with a compliance plan to run is covered in facility manager outreach. The message itself follows the rules in commercial HVAC cold email.

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Common questions

What is a building performance standard?

ENERGY STAR defines building performance standards as policies that require commercial and multifamily buildings to meet certain performance levels, typically for energy use or greenhouse gas emissions. A benchmarking law is narrower: it requires a building to measure and report its energy use, without a target to meet.

Does a building performance standard mean a building needs HVAC work?

No. It means the building's owner has a target and a date. Whether the building already meets it, and what, if anything, should change, is for the owner and their engineer to work out. A contractor who writes to an owner about a standard is writing about a public, dated fact, not about the state of the equipment.

Which buildings do these laws cover?

It depends on the law. In this table the size floors run from 5,000 square feet in Denver to 50,000 square feet in Colorado, St. Louis, Chicago and Washington's Tier 1, and several laws set different dates for different sizes. Each row gives the floor its official source states.

How can a commercial HVAC contractor use this table?

As a list of dated public facts that give an owner a reason to plan work, and you a reason to introduce yourself. Some laws ask for exactly what a maintenance agreement delivers: Washington's and Oregon's Tier 1 buildings need a written operations and maintenance program or plan. Mention the law as the reason you are writing, never as a verdict on the building.

How current is this table?

Every row was checked against its official source on the date shown on the page, and each row links that source. Laws change, deadlines move and extensions are granted, so open the source before you rely on any row.

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