The NYC Department of Buildings has extended the 2025 Energy Efficiency Report (EER) deadline under Local Law 87 from December 31, 2025 to March 31, 2026. While this provides immediate relief for building owners struggling to meet year-end compliance requirements, it also carries important implications for Local Law 97 emissions reporting and penalties.
Refresher: What Is Local Law 87?
Local Law 87 requires covered buildings to conduct energy audits and retro-commissioning every 10 years. Buildings submit Energy Efficiency Reports (EER) documenting their energy use, identifying efficiency opportunities, and demonstrating that building systems are operating as designed.
Covered buildings include:
- Buildings over 50,000 square feet (or 25,000 square feet for city-owned buildings)
- Two or more buildings on the same tax lot that together exceed these thresholds
Buildings are assigned to compliance groups based on the last digit of their tax block number, creating staggered 10-year cycles.
The Deadline Extension: Key Details
Original deadline: December 31, 2025
Extended deadline: March 31, 2026
Scope: 2025 filing year only (this is a one-time extension)
Penalties for Non-Compliance
Buildings that fail to submit by March 31, 2026 face civil penalties of $3,000 for the first year of non-submittal and $5,000 for each additional year of continued non-compliance.
Important: This extension does not change future Local Law 87 compliance cycles. Buildings due in 2026, 2027, and beyond will follow standard December 31 deadlines unless additional extensions are announced.
Why This Extension Matters for Local Law 97
The LL87 extension has strategic implications for buildings navigating Local Law 97 compliance, particularly those pursuing “good faith effort” pathways to defer penalties.
Understanding Local Law 97 Requirements
Local Law 97 establishes carbon emission limits for buildings over 25,000 square feet, with covered buildings that exceed annual emissions limits facing financial penalties of $268 per ton of CO2 equivalent over the limit.
The first compliance period began in 2024, with penalties taking effect in 2025. However, building owners can mitigate penalties and delay compliance until 2026 by demonstrating “good faith effort” to comply with emissions limits.
The Good Faith Effort Connection
To qualify for good faith effort penalty deferral, building owners must meet several requirements, including:
- Submit annual building emissions reports
- Comply with benchmarking under Local Law 84 and lighting/sub-metering requirements under Local Law 88
- Submit a Decarbonization Plan by May 1, 2025 demonstrating how the building will meet 2024 emissions limits by 2026
Here’s where LL87 becomes critical: Energy audits conducted under Local Law 87 provide essential data for creating accurate Decarbonization Plans. The energy efficiency measures identified in LL87 audits often form the foundation of LL97 compliance strategies.
How the Extension Affects LL97 Strategy
For buildings pursuing good faith effort deferrals:
The March 2026 LL87 extension creates a timing challenge. Buildings that haven’t completed their 2025 LL87 energy audits may lack comprehensive efficiency data when developing their May 2025 Decarbonization Plans for LL97.
Strategic consideration: Don’t wait until March 2026 to complete LL87 audits. Buildings planning LL97 good faith effort pathways should prioritize completing energy audits early to inform their Decarbonization Plans.
For buildings already exceeding LL97 limits:
According to city analysis, 11% of buildings are projected to exceed emissions limits for the 2024-2029 compliance period, and 63% are projected to exceed limits for the 2030-2034 period. For these properties, LL87 energy audit findings are critical for identifying cost-effective emissions reduction measures before penalties escalate in the 2030 compliance period.
The LL87 extension provides additional time to complete audits, but delaying until March 2026 means missing opportunities to implement recommendations before LL97’s more stringent 2030 limits take effect.
Managing Multiple Sustainability Deadlines
Between LL84 benchmarking (due June 30 annually), LL87 energy audits (10-year cycle), LL88 lighting and sub-metering, and LL97 emissions reporting and limits, NYC building owners face a complex web of overlapping sustainability requirements.
Prise centralizes all NYC energy and emissions compliance deadlines in one platform, tracking LL87 audit cycles, LL97 emissions reporting, and the interconnections between requirements. Our system flags when completing one requirement (like LL87 audits) strategically informs another (like LL97 Decarbonization Plans), helping you coordinate vendor engagement and maximize the value of compliance work.
For buildings navigating LL97 penalties or good faith effort pathways, Prise also offers violation remediation services, representing you in DOB proceedings to negotiate reduced penalties or establish practical compliance timelines.
Need help coordinating LL87 audits with LL97 compliance strategy? Contact Prise for guidance on navigating NYC’s interconnected sustainability requirements.
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