The annual cycle
NYC Admin Code §28-320.3.7 requires every covered Article 320 building to file an annual building emissions report covering the previous calendar year, due May 1 (NYC Admin Code §28-320.3.7; 1 RCNY §103-14(b)). The first reports — calendar-year 2024 — came due May 1, 2025; CY2025 reports were due May 1, 2026; the CY2026 report is due May 1, 2027, and the cycle repeats every year through the compliance periods.
The report is filed in DOB's BEAM portal and must be prepared by a registered design professional — a New York–licensed PE or RA (§28-320.3.7). DOB charges a filing fee of $210 for a simple report or $615 for a complex one (1 RCNY §101-03) — those are city fees set by rule, not anyone's pricing.
The data behind the report is the building's actual energy use for the calendar year — the same twelve months of utility data the building already benchmarks under Local Law 84. Buildings that wait for spring to assemble it are reconstructing a year of bills under deadline pressure; buildings that keep it current file on the first try.
After May 1
Two different clocks can start on May 2, and they are often confused:
| Late filing | Up to gross floor area × $0.50 per month until the report is filed — the maximum civil penalty for a late report (§28-320.6.2; 1 RCNY §103-14(g)(1)). This applies even if the building is under its emissions limit. |
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| Over the limit | An estimated maximum of $268 per metric ton of CO2e above the building's annual limit (§28-320.6) — a separate penalty, reported and assessed through the same annual filing. |
The statute gives a 60-day window after the deadline before a report is treated as not filed (§28-320.6.2), and the rule adds a formal extension: apply to DOB during the application window (a $60 filing (1 RCNY §101-03)), and an approved extension runs 120 days from May 1 — to August 29 (1 RCNY §103-14(g)(2)). An approved extension also covers an attached Good Faith Efforts mitigation filing (DOB LL97 Processing FAQs, 4/15/2026).
How DOB has actually run the first cycles
The first two filing years are worth knowing because they set expectations — and because DOB has said explicitly that first-year relief does not repeat.
| CY2024 → filed 2025 | Due May 1, 2025. BEAM, the filing portal, opened in March 2025 (DOB Service Notice 3/3/2025). DOB then extended the first cycle: apply by August 29, file by December 31, 2025 (DOB Service Notice 6/16/2025) — one-time, first-year relief. |
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| CY2025 → filed 2026 | Due May 1, 2026, with the standing mechanics: 60-day window to June 30, approved extensions to August 29, 2026 (DOB Service Notice 2/27/2026). DOB stated the 2025 service-notice extensions do not apply to filing year 2026. |
| CY2026 → filed 2027 | Due May 1, 2027 under the standard rule mechanics (§28-320.3.7; 1 RCNY §103-14(g)). Plan on the statutory dates — not on a repeat of 2025. |
Deferred schedules
Not every building's caps start in 2024, and the first report date moves with them:
Buildings with more than zero but no more than 35% rent-regulated units have their emissions caps begin with calendar year 2026, so their first report is due May 1, 2027 (§28-320.3.10.1; 1 RCNY §103-14(b)(8)(i)) — the same date as everyone else's CY2026 report, but their first.
Mitchell-Lama buildings that also contain income-restricted units face their first binding limits in the 2035–2039 period, first report due May 1, 2036 (§28-320.3.9). Both conditions are required — the statute is two-pronged.
Article 321 buildings (more than 35% rent-regulated, HDFC co-ops, and certain others) had a different obligation entirely: a one-time report due May 1, 2025 (§28-321.3), with a fixed $10,000 penalty for failing to file that attaches 60 days after the deadline (1 RCNY §103-17(d)(1)). If you are not sure which article your building falls under, start with the Article 320 vs 321 guide below.