Updated October 2026
Building energy regulations are the laws and programs that require owners to measure, report or limit the energy use and emissions of their buildings. They range from annual benchmarking and energy ratings to performance standards that fine buildings over a cap, and to corporate climate disclosure that puts building emissions into audited reports.
World29 rules
Building performance standards set a limit on each building's energy use intensity or emissions per square foot, and charge owners whose buildings run over the limit. Limits tighten with each compliance cycle, and most standards measure a full calendar year of actual operation.
Benchmarking laws require owners to report each building's annual energy use, usually through ENERGY STAR Portfolio Manager in the US. Rating and audit rules add a grade or an engineering review, and some require the rating to appear wherever a building is sold or leased.
Climate disclosure laws require large companies to publish their emissions, often with third-party assurance. For a real estate company, buildings produce most of the Scope 1 and Scope 2 emissions those reports cover.
Tax incentives, building codes and government retrofit programs shape how new buildings are designed and how existing buildings are upgraded, through deductions, permitting requirements and public retrofit targets.
Benchmarking ordinances, performance standards and energy codes in effect across selected US cities and states grew from 6 in 2008 to 64 by mid-2025. The count rose every year from 2012, with the most adoptions in 2019 and 2021.
| Year | Adopted | Repealed | In effect |
|---|---|---|---|
| 2008 | 4 | 0 | 6 |
| 2009 | 1 | 0 | 7 |
| 2010 | 2 | 0 | 9 |
| 2011 | 0 | 0 | 9 |
| 2012 | 1 | 0 | 10 |
| 2013 | 3 | 0 | 13 |
| 2014 | 1 | 0 | 14 |
| 2015 | 5 | 0 | 19 |
| 2016 | 5 | 0 | 24 |
| 2017 | 5 | 0 | 29 |
| 2018 | 3 | 0 | 32 |
| 2019 | 8 | 0 | 40 |
| 2020 | 3 | 0 | 43 |
| 2021 | 7 | 0 | 50 |
| 2022 | 6 | 0 | 56 |
| 2023 | 6 | 1 | 61 |
| 2024 | 2 | 0 | 63 |
| 2025 | 1 | 0 | 64 |
Source: Noda, The State(s) of Energy Policy (compiled Q2 2025), covering selected cities and states across eight US regions, with adoption years checked against city, state and IMT sources. South Portland, Maine repealed its ordinance in 2023. Figures for 2025 cover the first half of the year.
Select a milestone for the rule behind it.
Coverage, requirements, penalties and key dates for each rule, with the sources each entry draws on.
New York City
Local Law 97, part of New York City's Climate Mobilization Act, caps greenhouse gas emissions per square foot for most large buildings. Owners file an emissions report every May 1 for the previous calendar year. Limits for 2024 to 2029 were set so most buildings could meet them, and limits for 2030 to 2034 are far tighter: for offices, allowable emissions per square foot fall by about 46%.
Washington, DC
Washington, DC requires buildings that score below the city's performance standard to improve within each compliance cycle. Under the performance pathway, Cycle 1 calls for a site energy use intensity reduction greater than 20% against the 2018 to 2019 average, measured over calendar year 2026. A 2026 budget act moved the next cycle to January 1, 2029, when private buildings of 25,000 sq ft or more come into scope.
Boston
Boston's BERDO 2.0 combines yearly energy and emissions reporting with emissions standards that tighten in stages, ending at net zero in 2050. Larger buildings face standards from their 2025 emissions, and buildings of 20,000 to 35,000 sq ft or 15 to 34 units from 2030. Owners can meet part of a shortfall with an alternative compliance payment.
Denver
Energize Denver requires buildings of 25,000 sq ft or more to cut energy use intensity, and sets lighter requirements for buildings of 5,000 to 24,999 sq ft. The city revised the rules in April 2025 to add flexibility. A lawsuit by landlord and hotel groups against the policy and Colorado's statewide standard, refiled in August 2025, is pending, and in September 2026 the US Justice Department argued that federal energy law preempts the rules.
Maryland
Maryland's statewide standard, created by the Climate Solutions Now Act of 2022, covers commercial, multifamily and state buildings of 35,000 sq ft or more. Owners benchmark and verify their data each year, net direct emissions standards apply from 2030, and buildings reach net zero direct emissions in 2040. Buildings in Montgomery County follow the county's own program.
Washington State
Washington's Clean Buildings law sets energy use intensity targets for commercial buildings, and requires an energy management plan and an operations and maintenance program alongside them. Tier 1 covers non-residential buildings over 50,000 sq ft, phased in by size from 2026 to 2028, and Tier 2 brings in smaller commercial and multifamily buildings from 2027. A 2025 amendment added alternative compliance pathways, extensions and exemptions.
Seattle
Seattle's standard sets greenhouse gas emissions intensity targets for non-residential and multifamily buildings over 20,000 sq ft, reaching net zero between 2041 and 2050. Requirements open with reporting and planning from 2027 and move to emissions targets from 2031, largest buildings first. The city adopted its final rule for the first phase in December 2025.
New York City
Local Law 84 requires owners of large buildings in New York City to report energy and water use through ENERGY STAR Portfolio Manager by May 1 each year, and the city publishes the results. Local Law 133 of 2016 lowered the threshold from 50,000 to 25,000 sq ft. Under Local Law 33 of 2018 and Local Law 95 of 2019, covered buildings post a letter grade and ENERGY STAR score near each public entrance every October.
Colorado
Colorado requires most commercial, multifamily and public buildings of 50,000 sq ft or more to report energy use to the Colorado Energy Office each year and to meet a building-level energy use intensity or emissions target by 2030, measured against 2021. A 2025 law, HB25-1269, turned the 2026 interim target into a goal with no penalty, set penalties that begin in 2030, and started work on 2040 standards. Buildings that comply with Energize Denver meet the state targets.
Oregon
Oregon's Building Performance Standard, created by HB 3409 in 2023 and administered by the Oregon Department of Energy, requires nonresidential, hotel and motel buildings of 35,000 sq ft or more to meet a site energy use intensity target, or to complete an energy audit and carry out cost-effective efficiency measures. These Tier 1 buildings also submit an operations and maintenance plan and an energy management plan. Smaller commercial buildings and some larger building types, Tier 2, report energy use.
St. Louis
St. Louis requires owners of buildings of 50,000 sq ft or more to report energy and water use each year by May 1 and to meet a site energy use intensity target for their property type. Targets are set each five-year cycle so the worst-performing 65% of buildings must improve, and affordable housing and houses of worship run on seven-year cycles. The first compliance deadline passed in May 2025, and second-cycle targets were set in 2026.
Montgomery County, Maryland
Montgomery County requires most commercial and multifamily buildings of 25,000 sq ft or more to benchmark energy use each year by June 1, with third-party verification every three years, and to meet interim and final site energy use intensity standards by building group. Owners can instead follow an approved improvement plan built on an energy audit. Under a 2025 state law, buildings covered by the county program are exempt from Maryland's statewide BEPS.
California
SB 253 requires large companies doing business in California to publish their direct emissions and the emissions from the energy they buy, every year. The California Air Resources Board (CARB) approved its first regulation in February 2026, and the regulation took effect on October 12, 2026 with the first reports due November 10. SB 261, which calls for climate-risk reports from companies over $500M in revenue, is paused while the Ninth Circuit hears a challenge.
US federal
Section 179D lets commercial building owners, and designers of public and tax-exempt buildings, deduct part of the cost of qualifying lighting, HVAC and building envelope upgrades. The One Big Beautiful Bill Act of July 2025 ended the deduction for property whose construction begins after June 30, 2026. Projects that began construction by that date still qualify when placed in service.
US federal
EPA proposed closing ENERGY STAR in 2025, and more than 1,000 companies and cities urged it to keep the program. Congress set aside at least $33M for fiscal year 2026, and a March 2026 agreement made the Department of Energy the program's lead agency. Portfolio Manager, the benchmarking tool most US benchmarking laws require, continues to operate through the transfer.
European Union
The recast EPBD, Directive (EU) 2024/1275, is the EU's main law on building energy performance. Each member state writes it into national law, sets minimum energy performance standards for its non-residential buildings, and requires building automation and control systems in larger buildings where technically and economically feasible. In July 2026 the European Commission sent formal notices to all 27 member states for not fully transposing the directive by its deadline.
European Union
CSRD requires large companies to report sustainability information, including energy use and emissions, under the European Sustainability Reporting Standards. A 2025 stop-the-clock directive delayed the second wave of reporting by two years, and the 2026 Omnibus directive narrowed the companies in scope to the largest.
England and Wales
MEES sets a minimum Energy Performance Certificate rating for privately rented non-domestic property in England and Wales. Since April 2018 landlords cannot grant, extend or renew a lease below EPC E, and since April 2023 the minimum also applies to continuing lets unless an exemption is registered. In June 2026 the government confirmed its intention to require EPC B by 2031 for buildings over 1,000 m² where cost-effective, which still needs secondary legislation.
Global
GRESB is a voluntary, investor-driven benchmark that scores real estate funds and companies on ESG performance each year, and institutional investors use the results to compare managers. GRESB is moving its scoring toward measured energy and carbon performance, starting with the 2028 Standard.
United Arab Emirates
The UAE's climate law sets duties for emission sources on the mainland and in free zones, with no size threshold: measure and report Scope 1 and 2 emissions, keep five years of supporting records, and adopt a reduction plan aligned with sector targets. The duties take effect as the Ministry of Climate Change and Environment or an emirate authority designates each entity, and the law's executive regulation and reporting deadlines have yet to be published. Abu Dhabi applies a threshold of 25,000 metric tons of Scope 1 emissions a year.
Dubai
Dubai's Supreme Council of Energy runs Taqati, a voluntary program to cut the energy intensity of 30,000 existing buildings by 2030, delivered through Etihad ESCO. Al Sa'fat, Dubai Municipality's green building system, sets mandatory requirements for new construction at its Silver level, with Gold and Platinum optional.
Saudi Arabia
Saudi Arabia sets building energy requirements through the Saudi Building Code, whose energy conservation sections, SBC 601 for non-residential and SBC 602 for low-rise residential buildings, apply at design and permitting. The Saudi Energy Efficiency Center (SEEC) runs incentive programs, and the National Energy Services Company, Tarshid, holds the mandate to retrofit government buildings. Existing private commercial buildings carry no binding energy performance, benchmarking or audit obligation.
South Africa
South Africa requires owners of offices, places of instruction, and entertainment and public assembly buildings above size thresholds to obtain an energy performance certificate from a SANAS-accredited inspection body, display it at the main entrance, and lodge it with the South African National Energy Development Institute (SANEDI). Certificates grade buildings from A to G on energy use per square meter each year.
Singapore
Amendments to Singapore's Building Control Act target the city's most energy-intensive existing buildings. A building notified under the regime commissions an energy audit, submits an improvement plan within a year, delivers at least a 10% cut in energy use intensity within three years, and then holds the result for a further year.
Hong Kong
Hong Kong's Buildings Energy Efficiency Ordinance sets energy efficiency standards for building services and requires periodic energy audits. The 2025 amendment shortens the audit cycle from ten years to five, extends audits from 2 to 11 building types, including schools, hospitals, municipal buildings and railway stations, brings data centers of every size into scope, and requires audit reports to disclose more technical information.
Tokyo
Running since April 2010, Tokyo's program caps emissions from large offices, commercial buildings and factories, with tradable credits for facilities that beat their cap. Each five-year period has tightened the requirement, and the fourth period, fiscal 2025 to 2029, sets the steepest obligation yet.
Japan
Japan's Financial Services Agency is phasing in mandatory sustainability disclosure for Tokyo Stock Exchange Prime-market companies, under standards from the Sustainability Standards Board of Japan that follow the ISSB framework. The largest companies go first, and third-party assurance starts a year after each mandate.
Australia
Australia's climate disclosure regime requires companies above size thresholds to report under AASB S2, the Australian version of the ISSB climate standard, as part of their annual reports under the Corporations Act. Coverage widens in three groups through 2027, and assurance moves from limited to reasonable by 2030.
Australia
Under the Commercial Building Disclosure program, owners of office space of 1,000 m² or more obtain a Building Energy Efficiency Certificate, which pairs a NABERS Energy rating with a tenancy lighting assessment, before offering the space for sale or lease, and show the NABERS star rating in advertising. The threshold fell from 2,000 m² in 2017, and an October 2025 government roadmap proposes extending disclosure to large hotels, office tenancies and other building types.
A building performance standard (BPS) is a law that limits how much energy a building may use, or how much carbon it may emit, per square foot, and charges owners whose buildings exceed the limit. Most standards measure a full calendar year of actual operation, and limits tighten with each compliance cycle. New York City's Local Law 97, Washington, DC's BEPS and Boston's BERDO 2.0 are among the best known.
Benchmarking laws require owners to measure and report each building's annual energy use, usually through ENERGY STAR Portfolio Manager. A building performance standard sets a limit on that energy use or on emissions, with penalties for buildings that exceed it. Many cities began with benchmarking and later added a performance standard built on the same reported data.
Energy use intensity is a building's annual energy use divided by its floor area, usually stated in kBtu per square foot per year in the US and kWh per square meter per year elsewhere. Site EUI counts the energy measured at the building's meters, and source EUI adds the energy lost producing and delivering it. Washington, DC, Denver and Washington State set performance targets in EUI, while New York City and Boston limit emissions.
Buildings that exceed their emissions limit pay $268 for each metric ton of CO₂e over the limit, every year, and owners who fail to file face separate penalties. The limits for 2030 to 2034 are far tighter than those for 2024 to 2029: for offices, allowable emissions per square foot fall by about 46%.
This guide covers the standards in New York City, Washington, DC, Boston, Denver, Seattle, St. Louis and Montgomery County, and the statewide standards in Colorado, Maryland, Oregon and Washington State. Other cities and counties have adopted standards as well, and building energy policies in effect across selected US cities and states grew from 6 in 2008 to 64 by mid-2025.
Yes. EPA proposed closing ENERGY STAR in 2025, Congress then set aside at least $33M for fiscal year 2026, and a March 2026 agreement made the Department of Energy the program's lead agency, with the move due to finish by about August 2027. Portfolio Manager continues to operate through the transfer, and the local benchmarking laws that rely on it continue as before.
The EPBD requires each member state to renovate its worst-performing non-residential buildings, the bottom 16% by 2030 and the bottom 26% by 2033, and to require building automation and control systems where heating, cooling or ventilation systems exceed 290 kW, falling to 70 kW by the end of 2029. New public buildings must be zero-emission from 2028, and all new buildings from 2030. Member states had until May 29, 2026 to write the directive into national law.
After the 2026 Omnibus directive, CSRD applies to EU companies with more than 1,000 employees and more than €450M in net turnover, and to non-EU groups with more than €450M in EU turnover and an EU subsidiary or branch over €200M. Companies in the second wave report on financial year 2027, in 2028.
The Minimum Energy Efficiency Standards set a minimum EPC rating of E for privately rented commercial property in England and Wales, with penalties of up to £150,000. In June 2026 the government confirmed its intention to raise the minimum to EPC B by 2031 for buildings over 1,000 m², where cost-effective.
Noda reviews the guide once a year. Each entry states its facts as of the edition shown at the top of the page and lists the sources it relies on. Requirements can change between editions, so confirm deadlines and thresholds with the relevant authority before acting on them.
Noda reviews this guide once a year, checking every entry against official sources where they exist and against reputable legal and trade sources where they do not. This guide summarizes each rule for reference, and it is not legal advice.