Does my apartment building have to report its energy use to the city?
It does if your city has a benchmarking law and your building is over its size cutoff. New York City covers buildings over 25,000 gross square feet, Washington DC over 10,000 square feet, Seattle multifamily buildings over 20,000 square feet, and Boston residential buildings with 15 or more units. Each wants a yearly report of energy and water use, usually through the EPA's free ENERGY STAR Portfolio Manager.
What benchmarking asks you to do
Benchmarking means adding up a whole building's energy and water use for a calendar year and sending it to the city. The cities below all use ENERGY STAR Portfolio Manager, a free EPA tool: you create an account, describe the building (its floor area and how it is used), connect or enter the utility data, and submit a report to the city. Several cities then publish the results by address, so a buyer, a lender or a tenant can look your building up.
Small owners get caught by these laws for two reasons. First, the cutoffs are lower than many expect: a mid-size walk-up can cross them. Second, the notice often arrives as a line on a tax bill or a letter that looks like junk mail. Seattle even warns that private companies send benchmarking solicitations with wrong deadlines, and that the city's own letters never ask you to pay for a service (Seattle benchmarking).
Four cities side by side
| City | Who must report | Deadline | Cost of missing it |
|---|---|---|---|
| New York City (Local Law 84, amended by Local Law 133) | Buildings over 25,000 gross square feet, or two or more buildings on one tax lot over 100,000 together | May 1 each year | $500 for missing May 1, then $500 more at each missed quarterly deadline, up to $2,000 a year; $1,250 for not posting the energy grade |
| Washington DC | All buildings over 10,000 square feet | May 1 each year | Reported to DOEE; results are published on the city's building performance map |
| Seattle (SMC 22.920) | Multifamily and nonresidential buildings over 20,000 square feet, not counting parking | June 1 for the prior year | $2,000 a year for 20,000 to 49,999 square feet, $4,000 at 50,000 or more; $500 for an inaccurate report |
| Boston (BERDO) | Residential buildings with 15 or more units; nonresidential buildings of 20,000 square feet or more; a parcel whose buildings add up to either | May 15 each year | Set by the ordinance; covered buildings also face emissions limits that start in 2025 or 2030 |
As published by each city and read on 2026-10-30: New York City and its covered buildings, Washington DC, Seattle and its penalties, Boston. Other cities and some states have their own rules; check yours.
What each city adds on top
New York City
To find out whether you are covered, look on your Department of Finance property tax bill for a section called "One City Built to Last, Compliance Notification", or look up your borough, block and lot on the yearly Covered Buildings List. If you miss May 1, the next chances are August 1, November 1 and February 1. Under Local Law 33, the city also turns your ENERGY STAR score into a letter grade (A is 85 or more, B is 70 to 84, C is 55 to 69, D is below 55, F means you did not report) and you must print the label and post it near each public entrance within 30 days after October 1.
Washington DC
DC's cutoff is the lowest of the four, so far more small buildings are in. On top of the yearly report, DC requires the data to be checked by a third party: the next verification is due in 2027 for 2026 data, and then every six years. DC also runs a Building Energy Performance Standard, which asks buildings that score below the standard to improve over a compliance cycle.
Seattle
Fines are assessed 90 days after the June 1 deadline. For 2025 data, the city waived fines while owners move to its new Seattle Building and Energy Portal, which launched in July 2026; that waiver is for one year of data, so plan on the normal rules returning.
Boston
Boston counts units, not just square feet, which is why a 15 unit building is covered even if it is small. Beyond reporting, BERDO buildings must meet emissions standards that tighten over time, with every covered building expected to reach net zero emissions by 2050.
Is your building in? Two worked cases
Example a made-up 24 unit building with 22,000 gross square feet. In Boston it is covered, because 24 units is at least 15. In DC it is covered, because 22,000 is more than 10,000. In Seattle it is covered, because 22,000 is more than 20,000, and a missed year would cost $2,000. In New York City it is not covered, because 22,000 is not more than 25,000.
Example a made-up 12 unit building with 9,000 square feet. It is under every cutoff in the table: 12 units is fewer than Boston's 15, and 9,000 square feet is under DC's 10,000, Seattle's 20,000 and New York's 25,000. If the same owner had a New York building that missed every deadline in a year, the fines would be $500 for May 1 plus $500 each for August 1, November 1 and February 1, which is $2,000, the yearly cap.
Use the floor area the city uses. New York goes by the Department of Finance records, and if you think the square footage there is wrong, the city tells you to dispute it with Finance rather than ignore the notice.
Filing your first report, step by step
- Confirm you are covered: check the city's covered buildings list or your tax bill, using the city's floor area figure.
- Create an ENERGY STAR Portfolio Manager account and add the property with its floor area and use (multifamily housing).
- Get whole-building data. New York notes that most utilities upload whole-building energy and water data to Portfolio Manager for you once the account is linked; where tenants pay their own electric, ask the utility how it shares building totals.
- Check the year for gaps, such as a missing month or a meter that changed, before you submit.
- Submit the city's reporting template from Portfolio Manager and save the confirmation email.
- Calendar next year's deadline, plus New York's October label window or DC's verification year if they apply.
Where DoorKeeping fits
DoorKeeping reads each utility bill with AI and codes it to that property's utilities account, so a year of electric, gas and water bills is one question away when you sit down with Portfolio Manager. Keep the submission confirmation, the grade label and any city letters in the property's documents. DoorKeeping costs $2 per unit per month, with no other fees for owners or tenants. It does not file benchmarking reports for you.
Sources
- NYC Department of Buildings, Benchmarking and Energy Efficiency Rating, read Oct 30, 2026
- NYC Department of Buildings, LL84 Benchmarking Law (covered buildings), read Oct 30, 2026
- DC Department of Energy and Environment, Building energy benchmarking, read Oct 30, 2026
- City of Seattle, Energy Benchmarking, read Oct 30, 2026
- City of Seattle, Energy Benchmarking Penalties, read Oct 30, 2026
- City of Boston, Building Emissions Reduction and Disclosure (BERDO), read Oct 30, 2026
Questions
- What size apartment building has to benchmark in New York City?
- Buildings over 25,000 gross square feet, as shown in Department of Finance records, plus two or more buildings on one tax lot that together exceed 100,000 square feet. Reports are due May 1.
- Does a 15 unit building have to report under Boston's BERDO?
- Yes. BERDO covers residential buildings with 15 or more units, whatever their square footage, and annual reports are due May 15.
- What is the fine for not benchmarking in Seattle?
- Seattle assesses $2,000 a year for buildings of 20,000 to 49,999 square feet and $4,000 for 50,000 or more, 90 days after the June 1 deadline. Fines for 2025 data were waived during the move to a new portal.
- Does it cost money to benchmark?
- ENERGY STAR Portfolio Manager is free. DC requires third-party verification on a six-year cycle, which you pay for, and some owners hire help, but the report itself has no filing fee in these cities.