Local Law 97 in 2026!
What Property Owners Need to Know:
New York City building owners subject to Local Law 97 are approaching an important reporting deadline.
Owners who obtained a 2026 reporting extension must submit their Local Law 97 compliance reports by August 29, 2026. The report covers the building’s greenhouse-gas emissions during calendar year 2025 and generally must be certified by a registered design professional.
Owners should treat Local Law 97 as an ongoing building-performance requirement—not simply an annual administrative filing. Buildings that exceed their applicable emissions limits may face substantial yearly penalties, while owners who fail to submit the required report may incur monthly penalties based on the building’s floor area.
What Is Local Law 97?
Local Law 97 was adopted as part of New York City’s Climate Mobilization Act. It requires most large buildings to remain below annual greenhouse-gas emissions limits, with the limits becoming significantly stricter beginning in 2030.
According to the NYC Department of Buildings, more than two-thirds of New York City’s greenhouse-gas emissions come from buildings. Local Law 97 is intended to reduce emissions from the city’s largest buildings by 40 percent by 2030 and move toward net-zero emissions by 2050.
Compliance began with calendar year 2024 emissions. Covered building owners must now submit a certified emissions report every year.
Which Buildings Are Covered?
Local Law 97 generally applies to:
A single building exceeding 25,000 gross square feet.
Two or more buildings on the same tax lot that together exceed 50,000 gross square feet.
Two or more condominium buildings governed by the same board of managers that together exceed 50,000 gross square feet.
The square footage shown in NYC Department of Finance records is initially used to determine whether a property may be covered.
However, appearing—or not appearing—on DOB’s Covered Buildings List does not conclusively determine an owner’s legal obligations. Owners remain responsible for verifying their building’s size, occupancy, tax-lot configuration and applicable compliance pathway.
The 2026 Covered Buildings List also includes certain buildings with rent-regulated dwelling units that were not subject to the standard Article 320 requirements during the first compliance year.
What Is the 2026 Reporting Deadline?
Article 320 generally requires covered building owners to file their annual emissions report by May 1. For the 2026 filing year, DOB provided:
An original filing deadline of May 1, 2026.
A 60-day grace period through June 30, 2026.
An extended deadline of August 29, 2026, for owners who properly requested the 120-day extension by June 30.
The August 29 deadline does not automatically apply to every covered building. It applies to owners who completed the required extension process.
Reports are submitted through DOB’s Building Energy Analysis Manager, commonly known as the BEAM portal.
What Must the Annual Report Include?
The annual report generally documents the building’s energy consumption and resulting greenhouse-gas emissions for the preceding calendar year.
The compliance process may include:
Confirming the building’s applicable Local Law 97 pathway.
Reviewing the current Covered Buildings List.
Verifying building and tax-lot information.
Reviewing utility and energy-consumption records.
Coordinating information reported through ENERGY STAR Portfolio Manager.
Confirming the building’s gross floor area and occupancy classifications.
Calculating the applicable emissions limit.
Calculating the building’s actual annual emissions.
Identifying available deductions, credits or alternative compliance provisions.
Obtaining certification from a registered design professional.
Paying the required DOB filing fee.
Submitting the completed report through BEAM.
Buildings with multiple occupancies, multiple structures on one tax lot, shared energy services or unusual property configurations may require additional analysis.
What Are the Penalties?
For buildings subject to Article 320, DOB identifies two principal penalty categories.
Failure to Submit the Annual Report
The penalty for failing to file is calculated as:
Building floor area × $0.50 per month
For example, a 100,000-square-foot building could face a penalty of $50,000 for every month the required report remains unfiled.
Exceeding the Building’s Emissions Limit
The annual penalty is calculated as:
Actual emissions minus the applicable emissions limit × $268 per metric ton of carbon-dioxide equivalent
A building exceeding its limit by 100 metric tons could therefore face an annual penalty of $26,800.
Separate requirements and penalties apply to certain affordable housing properties and houses of worship subject to Article 321.
Submitting a report does not, by itself, establish that a building complies with its emissions limit. The report must accurately document the building’s energy usage, emissions and compliance status.
What Should Owners Do Before August 29?
Owners who requested an extension should immediately confirm that the complete report can be certified and submitted before the deadline.
Recommended steps include:
Confirm that the building is covered.
Review the 2026 Covered Buildings List and verify the building’s recorded information, square footage and compliance pathway.Confirm the extension status.
Verify that the extension request was properly submitted through DOB NOW and BEAM.Review energy records.
Confirm that utility data for electricity, natural gas, steam and fuel oil is complete and consistent with ENERGY STAR Portfolio Manager.Engage the required professionals.
Most Article 320 filings require certification by a New York State registered architect or professional engineer. Depending on the building, an energy consultant or mechanical engineer may also be needed.Calculate the emissions limit and potential exposure.
Owners should know whether the building is below its limit, how far it may be above the limit and what penalties could result.Document compliance measures and good-faith efforts.
Maintain records of energy audits, retrofit planning, contracts, capital budgets, equipment replacement, financing applications and completed efficiency improvements.Submit before the deadline.
Do not wait until August 29 to resolve account, payment, professional-certification or data discrepancies.
What If a Building Exceeds Its Limit?
A building that exceeds its annual emissions limit should develop a practical decarbonization plan.
Potential improvements may include:
Replacing inefficient boilers, chillers and HVAC equipment.
Converting fossil-fuel equipment to high-efficiency electric systems.
Improving insulation and the building envelope.
Replacing or improving windows and exterior doors.
Upgrading lighting and controls.
Installing energy-management and building-automation systems.
Commissioning or retro-commissioning mechanical systems.
Installing or purchasing qualifying renewable energy.
Coordinating available incentive, financing or offset programs.
The best solution will depend on the building’s construction, occupancy, existing mechanical systems, energy usage, available electrical capacity and capital-improvement schedule.
Why Owners Should Begin Planning for 2030 Now
The current emissions limits apply through 2029. More restrictive limits begin in 2030, meaning that a building complying today may not comply during the next emissions period.
Major mechanical, electrical and building-envelope improvements can require:
Existing-condition surveys.
Feasibility studies.
Capital planning and budgeting.
Architectural and engineering drawings.
Utility coordination.
DOB and other agency approvals.
Tenant coordination.
Equipment procurement.
Phased construction.
Testing, inspections and final sign-offs.
Waiting until 2029 may leave insufficient time to design, approve, finance and construct the required improvements.
How SWA Architecture Can Help
SWA Architecture can assist owners and property managers with the architectural and agency-coordination components of Local Law 97 planning, including:
Existing-condition assessments.
Review of building records and Certificates of Occupancy.
Building-envelope and renovation planning.
Architectural drawings for energy-efficiency improvements.
Coordination with mechanical, electrical and energy consultants.
DOB filing and permit coordination.
Phased retrofit and tenant-coordination planning.
Construction administration and project closeout.
Local Law 97 compliance requires coordination among ownership, property management, registered design professionals, energy consultants and contractors. Establishing a coordinated plan now can help owners reduce compliance risk, avoid rushed capital projects and prepare for the stricter limits taking effect in 2030.
This article is provided for general informational purposes and does not constitute legal, engineering or energy-consulting advice. Local Law 97 requirements vary according to the property, ownership structure, occupancy, building systems and applicable compliance pathway.
Contact SWA Architecture at 212-932-7566 or info@swaarchitecture.com to schedule a Place of Assembly compliance review