NYC building energy & emissions laws:
every requirement, deadline and fine.

Each law asks a different question of the same building. LL84 asks how much energy and water it used last year (DOB Benchmarking page). LL33 turns that answer into a letter grade posted near each public entrance (NYC Admin Code §§28-309.12.1, 28-309.12.3 (LL33/2018, as amended by LL95/2019)). LL87 asks, once every ten years, what an energy audit and retro-commissioning found (NYC Admin Code §§28-308.2, 28-308.3, 28-308.4 (LL87/2009)). LL88 required lighting upgrades and tenant sub-meters by January 1, 2025 (NYC Admin Code §28-310.3 (as amended by LL134/2016); §28-311.3 (as amended by LL132/2016)). And Local Law 97 caps the building's annual greenhouse-gas emissions from calendar year 2024 (NYC Admin Code §28-320.3 (LL97/2019)).

Square footage is measured as it appears in Department of Finance records (NYC Admin Code §28-309.2 (as amended by LL133/2016)), and DOB publishes a new benchmarking Covered Buildings List each year (DOB LL84 Benchmarking Law page). The detail behind every cell — deferred cohorts, statutory exceptions and extension mechanics — lives on each law's own page.

Coverage is decided by gross floor area, and the thresholds are not identical across the five laws. Four of them start at 25,000 gross square feet; LL87 starts at 50,000. The multi-building tests differ too: for LL84, LL87 and LL88, two or more buildings on one tax lot — or two or more condominium buildings under one board — are covered when they together exceed 100,000 gross square feet, but LL97 draws that line at 50,000.

The LL97 exception list has been amended since 2019 (NYC Admin Code §28-320.1 (as amended by LL147/2019)), and DOB states that Article 321 covers certain affordable housing and houses of worship, under its own rule, 1 RCNY §103-17 (DOB LL97 page) — read exemptions and covered buildings and Article 320 vs 321 before assuming a building is out.

DOB's February 2026 service notice sets the year's dates in one place, and states that the deadline extensions issued by service notice in 2025 do not apply to 2026 (DOB Service Notice 2/27/2026). Plan on these:

Every one of these dates, with the citation behind it, is on the compliance calendar. If the LL97 date is the one that worries you, the free LL97 calculator estimates a building's exposure from its address.

The fines are as different in shape as the laws themselves, and the shape matters more than the headline number.

Three are fixed-dollar. Failing to benchmark is classified by the statute as a “lesser violation” (NYC Admin Code §28-309.4.3), with the amounts set by rule: $500 for missing May 1 plus $500 for each additional quarterly violation (1 RCNY §103-06(l)(1)), which DOB's benchmarking page describes as up to $2,000 per year (DOB Benchmarking page (1 RCNY §103-06)). LL33 is $1,250 per violation for failing to print and post the label, and a challenge must be filed within 30 days of the notice's postmark (1 RCNY §103-06(l)(2); DOB LL33 Energy Grading Violations page). LL88 is $1,500 for each unfiled report — the lighting report and the sub-meter report are separate — assessed annually until the report is filed, plus $500 for each covered tenant space lacking a required sub-meter, also assessed annually (1 RCNY §103-18(c), (e)(1), (e)(2)).

LL87 escalates: failing to file the Energy Efficiency Report is a Major (Class 2) violation of $3,000 in the first year and $5,000 for each additional year until it is submitted (DOB LL87 Violations page (1 RCNY §103-07)).

LL97 scales with the building. Exceeding the limit costs up to $268 per metric ton of CO2e over it (NYC Admin Code §28-320.6; 1 RCNY §103-14(h)); failing to file costs up to gross floor area × $0.50 for each month the report is late, for up to 12 months (NYC Admin Code §28-320.6.2; 1 RCNY §103-14(g)(1)); and a knowingly false statement is a misdemeanor with a fine of up to $500,000, up to 30 days' imprisonment, or both (NYC Admin Code §28-320.6.3). Article 321 buildings face a flat $10,000 per covered building for failing to file the Article 321 report within 60 days of the deadline, or by any extension deadline DOB grants, and a separate $10,000 per covered building for failing to demonstrate compliance with either pathway (1 RCNY §103-17(d)(1), (e)). The penalty mechanics page shows the math, and the calculator runs it for a specific address.

The five laws are not five separate data sets. The benchmarking submission a building makes under LL84 is the input for two of the others.

The energy grade is, in the statute's words, “a grade based on an energy efficiency score assigned through the benchmarking tool” — the ENERGY STAR score Portfolio Manager generates from the LL84 submission (NYC Admin Code §28-309.12.1 (as amended by LL95/2019)). A score of 85 or higher is an A, 70–84 a B, 55–69 a C and below 55 a D; a building that did not submit its benchmarking data by May 1 gets an F, and one that is exempt or cannot be scored gets an N (NYC Admin Code §28-309.12.1 (LL95/2019); DOB 2025 Benchmarking presentation). LL95 of 2019 raised those cut-offs from LL33's original 90, 50 and 20 (Local Law 95 of 2019 §1). The label posted each October carries an earlier year's grade — the label due by October 31, 2022, for example, showed the building's 2021 grade (DOB Service Update 10/11/2022). Skip benchmarking, and the F at the front door follows automatically.

LL97 draws on the same data. DOB's Article 320 guide says a typical building's initial annual report would use its 2024 benchmarking data and would be due May 1, 2025 (DOB Article 320 Info Guide v1.4 (6/30/2025)), and the statute requires DOB to provide a method for converting Portfolio Manager use categories into the occupancy groups that set each building's emissions limit (NYC Admin Code §28-320.3.1). The difference is what happens to the data: LL84 reports it, LL97 caps it. LL97 also adds a certification step — the annual report must be certified by a registered design professional (NYC Admin Code §28-320.3.7) — and a filing fee of $210 for a simple report or $615 for a complex one (1 RCNY §101-03). DOB reported in April 2026 that approximately 93% of covered privately owned properties, representing 91% of covered buildings, had filed their first LL97 reports (DOB press release 4/22/2026).

LL87 and LL88 sit outside that annual loop. LL87 is cyclical — one Energy Efficiency Report every tenth year, filed by a registered design professional (NYC Admin Code §§28-308.2, 28-308.3, 28-308.4; DOB LL87 page), with up to two one-year extensions for owners who cannot finish despite good-faith efforts, neither of which shifts the next due date (NYC Admin Code §28-308.4, Exception 1). LL88 was a one-time deadline — lighting to NYC Energy Conservation Code new-system standards and sub-meters in every covered tenant space by January 1, 2025, with reports due May 1, 2025 (NYC Admin Code §28-310.3 (as amended by LL134/2016); §28-311.3 (LL88/2009); 1 RCNY §103-18(b), (d)) — whose penalties recur every year until the reports are filed (1 RCNY §103-18(c), (e)(1)). Lighting inside dwelling units classified in occupancy group R-2 or R-3 is exempt from the upgrade; LL134 of 2016 removed the original exemption for the spaces serving those units, such as hallways, laundry rooms and boiler rooms (NYC Admin Code §28-310.3, Exceptions (dwelling-unit exception, as amended by LL134/2016 §2)), which makes LL88 lighting a commercial and common-area requirement.

One page per law, each verified against the rule text and DOB's current notices.

• Local Law 84: Benchmarking

  Annual energy and water benchmarking in ENERGY STAR Portfolio Manager — who is covered, the May 1 deadline, and the fines.

• Local Law 33: Energy Grades

  The A–F building energy efficiency grade — how it is scored from benchmarking, where it must be posted, and the posting fine.

• Local Law 87: Audits & Retro-commissioning

  The 10-year energy audit and retro-commissioning cycle — which year your block number is due, what the report contains, and the penalties.

• Local Law 88: Lighting & Sub-metering

  The lighting upgrade and tenant sub-metering requirements, the 2025 deadlines, and the reporting fines.

• NYC Building Compliance Calendar

  Every LL84, LL33, LL87, LL88 and LL97 deadline in one place, with the citation behind each date.

• Financing & Incentives

  NYC Accelerator, C-PACE, the J-51 R tax benefit and utility programs that can help pay for compliance work.

LL97 is the one law of the five whose penalty scales with the building and recurs every year, so it has its own hub and guide library:

• LL97 Deadlines

  The annual May 1 filing cycle, the late-filing accrual, extensions, and how DOB has handled the first cycles.

• How LL97 Penalties Are Calculated

  The $268/ton mechanics with the math shown — limits, coefficients, and a worked example across 2024–2029 and 2030–2034.

• Article 320 vs Article 321

  Who has no annual cap, the prescriptive and performance routes, and the one-time §28-321.3 report.

• Good Faith Efforts

  What qualifies under 1 RCNY §103-14(i)(2), what mitigation can and cannot buy, and the filing mechanics.

• Who Certifies an LL97 Filing

  The registered design professional requirement — what a PE/RA reviews before signing, and why formula lineage matters.

• LL97 for Co-ops & Condos

  Who the law treats as the owner, what the board must file, the 50,000 sq ft multi-building rule, and where HDFCs and rent-regulated buildings land.

• The 2030–2034 Limits

  How the 2030 caps are set, the property-type coefficients against today's, and a worked example of what flat emissions cost after 2029.

• How to File an LL97 Report

  Step by step through DOB NOW and BEAM: what the report contains, the fees, the RDP certification, extensions, and mitigation attachments.

• Exemptions & Covered Buildings

  The 25,000 sq ft test, the annual Covered Buildings List, the statutory exceptions, and the deferrals for rent-regulated and income-restricted housing.

• RECs & Offsets

  What renewable energy credits and greenhouse gas offsets can and cannot do under §28-320.3.6, and the limits the rule puts on them.

• LL97 FAQ

  Straight answers to the questions owners, boards and managers actually ask — every one cited to the law, the rule, or DOB.