Building performance standards (BPS) are evolving quickly, and for many property owners and managers, the biggest challenge is keeping track of changing deadlines, reporting requirements, and compliance pathways. Delaying benchmarking, data verification, or performance planning until the last minute often creates unnecessary operational strain, compliance risk, and penalties.
At the same time, efficient, high-performing buildings are becoming increasingly valuable assets. Benchmarking and BPS compliance not only support regulatory requirements, but also help owners identify operational inefficiencies, reduce utility costs, and strengthen long-term asset value.
Here are the most important changes, deadlines, and actions building owners should be aware of during the 2026 compliance season.
Immediate Compliance Priorities
June 1 Compliance Cluster
Many major benchmarking and building performance programs share a June 1 deadline. Building owners should confirm immediately whether their property is covered and what submissions are required.
Programs with June 1 deadlines include:
- Los Angeles Existing Buildings Energy and Water Efficiency (EBEWE)
- California Assembly Bill 802 (AB802)
- Seattle Building Emissions Performance Standards (BEPS)
- Washington Clean Building Performance Standards (CBPS)
- Montgomery County Building Emissions Performance Standards (BEPS)
- Maryland Building Energy Performance Standards (BEPS)
- Minnesota Large Building Benchmarking
- Oregon Building Energy Performance Standards (BEPS)
- Energize Denver
- Aspen Building IQ
- Chicago Energy Benchmarking Ordinance
- Minneapolis Building Rating and Disclosure Policy
- Atlanta Energy Benchmarking
- Austin Energy Conservation Audit and Disclosure Ordinance (ECAD)
- Detroit Energy and Water Benchmarking Ordinance
- Columbus Energy and Water Benchmarking and Transparency Policy
- Edina Efficient Buildings Ordinance (EBO)
- Indianapolis Thriving Buildings Program
- San Diego Building Energy Benchmarking Ordinance (BEBO)
- Ann Arbor Energy and Water Benchmarking and Disclosure Ordinance
- Fort Collins Building Energy and Water Scoring (BEWS)
Depending on the jurisdiction, requirements may include:
- Energy benchmarking
- Water benchmarking
- Third-party data verification
- Energy audits
- Performance target compliance
- Retro-commissioning
- Energy management plans
- Operational and maintenance tune-ups / implementation
Critical Policy Changes Owners Need To Know
Building Performance Colorado (BPC) Updates
Colorado’s House Bill 25-1269 introduced several major changes to Building Performance Colorado:
- Annual reporting deadline permanently moved to November 1
- 2026 performance targets changed from mandatory targets to interim goals through 2030
- Buildings may now use a 2019 baseline year instead of 2021
- New enterprise fund established to support compliance guidance and funding
- Special target pathways available for buildings with data centers
- Process established for future 2040 performance targets
One important clarification: while the reporting period now runs from July 1 through November 1, the submitted benchmarking data still reflects the previous calendar year.
Energize Denver Deemed Compliance
Energize Denver became the first program approved for “deemed compliance” under Building Performance Colorado. Covered buildings do not need to separately comply with BPC performance requirements, but owners must still:
- Submit benchmarking data to both agencies
- Pay applicable fees to both programs
Energize Denver Verification Deadline
Energize Denver requires one benchmarking report to be third-party verified by 2026. For any covered building that has not yet completed verification, this is the final compliance year to do so.
Washington State Clean Building Performance Standards (CBPS) Updates
Washington’s House Bill 1543 introduced several important updates to Clean Building Performance Standards (CBPS), including:
- Alternative energy and greenhouse gas compliance pathways
- Additional hardship and historic-building exemptions
- New deadline extension opportunities
- Protections preventing owners from passing penalties onto cooperative tenants
- Expanded utility data access requirements
- Future Tier 2 building performance standards by 2030
New Ordinances Entering First Compliance Years
New Orleans Building Energy Benchmarking Ordinance
Buildings over 50,000 sq. ft. must begin annual energy reporting by May 31, 2026.
Lakewood Building Performance Program
Lakewood adopted a new Energy Benchmarking Ordinance requiring buildings over 10,000 sq. ft. to report annual energy use. The first compliance deadline is December 31, 2026.
Additional 2026 Building Performance Deadline Changes
Several jurisdictions extended or adjusted reporting timelines for 2026:
Program
Building Performance Colorado (BPC)
Maryland BEPS
West Hollywood EBPS
Boston BERDO
2026 Deadline Update
Deadline permanently moved to November 1
Reports submitted by June 30 will be considered timely
Deadline extended to September 15
Deadline extended to August 15
Why Compliance Matters Beyond Avoiding Penalties
The risks of non-compliance are top of mind for most building owners. The potential financial exposure of is substantial: California’s statute authorizes fines up to $2,000 per category of non-compliant data per day, and Seattle’s rules allow a $5,000 base fine plus $1 per square foot per day. Enforcement has historically been uneven but building performance policies are no longer just reporting exercises. They are becoming operational performance standards that directly impact:
- Asset value
- Operating expenses
- Financial & Regulatory Risk
- Tenant expectations
- Capital planning
- Market competitiveness
Benchmarking and verification provide building owners with measurable insight into how efficiently their properties operate. Energy audits and performance improvements can uncover opportunities to reduce waste, lower utility costs, and improve long-term building performance.
As regulations continue to evolve, proactive compliance planning is becoming a critical part of protecting and improving real estate investments.
What Building Owners Should Do Right Now
Property owners and managers should immediately confirm:
- What is required for each covered building this year?
- Were there any recent policy or deadline changes in the jurisdiction?
- Who is actively managing compliance and reporting?
The most important first step is establishing ownership of the compliance process. The building owner remains responsible for compliance, but consultants like VCA Green can help reduce the workload, manage the process, and stay on top of changing policies as they report on the owner’s behalf.
With multiple jurisdictions updating policies and deadlines simultaneously, waiting until the final weeks before submission can create unnecessary risk, operational disruption, and missed opportunities to improve building performance.
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