Property Size

All privately owned commercial and multifamily buildings 10,000 Sq. Ft. or larger.

Annual benchmarking reporting requires 12 calendar months of whole-building energy, water, and building use data. For example, in 2025, building owners must report 12 months of 2024 data.

May 1, annually. Benchmarking reports must be submitted on an annual basis using the previous year’s data via ENERGY STAR® Portfolio Manager®. This is the EPA’s benchmarking tool that is used for compliance reporting in most ordinances across the country.

Building Performance Standards (BPS) are often considered Phase II of these building energy use ordinances. After reporting your benchmarking data, many ordinances require you to make changes to the building’s operations or equipment to lower energy use over time.

Washington DC BEPS requires covered properties to meet performance standards every 6 years. Specific standards vary per building type. Compliance is measured by performing below the designated Source EUI or achieving a certain ENERGY STAR Score (if applicable).

Buildings who are not in compliance at the start of a BEPS cycle must submit and maintain a compliance pathway throughout the rest of the cycle.

BEPS Period 1 (2021-2026)

• Private buildings over 50,000 Sq. Ft.
• DC-owned buildings over 10,000 Sq. Ft.

Data will be evaluated in 2027 benchmarking reports.

BEPS Period 2 (2028-2032)

• Private buildings over 25,000 Sq. Ft.
• DC-owned buildings over 10,000 Sq. Ft.

Data will be evaluated in 2033 benchmarking reports.

BEPS Period 3 (2034-2038)

• Private and DC-owned buildings over 10,000 Sq. Ft.

Data will be evaluated in 2039 benchmarking reports.

Third-party data verification requires owners/managers of covered buildings to hire a third-party expert who will independently review and verify the building’s benchmarking data.

Under Washington DC BEPS, data verification is required every 6 years from the first verification year. Verification must be submitted on the May 1 reporting deadline of each verification year. Data verification requirement start schedule:

• Buildings over 25,000 Sq. Ft. begin in 2024 (2023 data)
• Buildings over 10,000 Sq. Ft. begin in 2027 (2026 data)

BEPS Alternative Compliance Penalties:

• Maximum penalty is $10 per Sq. Ft.
• Penalty reductions will be made relative to the amount of Site EUI reduced in the BEPS cycle

BEPS Civil Infractions:

• $2000: Implementation of a compliance measure that poses a threat to the health and safety of a building occupant
• $1000: Failure to submit selection of a Compliance Pathway
• $500 for failure to submit each of the following:
  • A report on completed actions (Performance and Standard Target Pathways)
  • An energy audit (Prescriptive Pathway)
  • An action plan (Prescriptive Pathway)
  • An implementation report (Prescriptive Pathway)
  • An evaluation, monitoring, and verification report (Prescriptive Pathway)
  • Additional documentation (Prescriptive Pathway)
  • Documentation (All Pathways)
  • A complete and accurate plan or report or complete and accurate documentation (All Pathways)
  • Failure to provide the buyer of a building with information prior to a transfer or sale (All Pathways)

CONTACT US HERE to learn more and get started with compliance.

Washington DC BEPS compliance can be confusing and hard to navigate. Bringing on a consultant like VCA Green streamlines the entire process while ensuring accurate reporting. We also offer free consultations with our benchmarking clients to review the reports and identify inefficiencies to improve.

Ordinances such as Washington DC BEPS are already in effect across the country, and deadlines are rapidly approaching. Retrieving historical building data will take time, especially when coordinating with property managers and utilities.

Waiting until the last minute risks missing compliance windows resulting in fines and enforcement penalties. VCA Green takes every measure to ensure complete and accurate data collection. The sooner you reach out, the sooner you will reach compliance.