NATIONWIDE BENCHMARKING

NATIONWIDE
BENCHMARKING

What is Benchmarking?

Energy benchmarking is a process used to evaluate and compare the energy performance of buildings, facilities, or processes against established standards or similar entities. It involves measuring and analyzing energy consumption data to understand how efficiently a building or system uses energy compared to others of similar size, type, or function.

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Energy benchmarking is often required by cities, municipalities, or lenders for large buildings across the country.   There are also various voluntary certification programs as a means of demonstrating compliance or achieving recognition for energy efficiency efforts.

Carleton Energy Consulting has Certified Energy Managers , authorized by the Association of Energy Engineers (AEE), on staff who will ensure your property is in compliance and all data is officially verified to avoid any future violations.

BENCHMARKING COMPLIANCE

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NATIONWIDE INTERACTIVE MAP

*Click on the Icon Marker below on the Interactive Map for a direct link to the Market Specific Ordinance.

Nationwide Benchmarking

CALIFORNIA

California Assembly Bill 802

Owners of buildings larger than 50,000 square feet are required to submit whole building monthly energy use data to the Energy Commission.

Benchmarking filing is due June 1st of each year.

The Commission has the authority to institute civil fines of up to $2,000 for non-compliance.

Berkeley, CA (BESO)

All buildings 15,000 sq ft or above are required.

Benchmarking filing is due July 1st of each year.

Violations and Penalties: There are fines of $100 for each violation and an additional fine of up to $25 per day for each day that the violation continues, up to a maximum of $1000 per violation.

Brisbane CA

Applies to commercial, industrial, and multifamily buildings of 10,000 square feet or larger.

Due May 15 every year. 

The amount of fines is between US$100 – US$500 per violation

LOS ANGELES, CA

All buildings equal or over 20,000 square feet are required.

Benchmarking filing is due June 1st of each year.

The EBEWE Ordinance puts the initial non-compliance fee at $202.  An additional 250% late charge/collection fee within 30 days of the date of the initial invoice will be imposed and assignment to a collection agency may be made.  Interest will then continue to accrue annually until this invoice and additional charges have been paid.

San Diego, CA

Applies to commercial, multifamily, and mixed‑use buildings in the City of San Diego that are 50,000 square feet or larger

Annual submission deadline: June 1 each year.

The fines for non-compliance are up to $1,000

San Francisco, CA

California AB802 is a state law that requires commercial and multifamily buildings 50,000 gross square feet or larger to benchmark energy use. Submitting one annual benchmark report to San Francisco satisfies both local and state regulations. 

Benchmarking filing is due April 1st of each year.

Owners of buildings greater than 50,000 square feet in size are subject to a $100 per day fine, limited to 25 days per year, or a maximum fine for non-compliance of $2,500 per annum.

San Jose, CA

Commercial and multifamily buildings that are 20,000 sq ft or larger

Due by May 1st each year

For buildings
under 50,000 square feet, non-compliance can lead to a fine of $25/day, up to $2,500 per year.

For buildings 50,000 square feet or more, the fine is $50/day, up to $5,000 per year.

COLORADO

Building Performance Colorado

(Benchmarking + Performance Standards)

Applies to commercial, multifamily, and public buildings 50,000 sq ft or larger.

Due June 1st of each year. 

Late Benchmarking/reporting failures:

Up to $500 for a first violation.

Up to $2,000 for each subsequent violation

Failure to meet Building energy performance standards:

Up to $2,000 for a first violation.

Up to $5,000 for subsequent violations

Aspen, CO

Non‑city commercial properties ≥ 5,000 sq ft  Multifamily properties ≥ 15,000 sq ft

Annual benchmark submission deadline: June 1 each year.

$100 for the first offense, $200 for the second offense, and any additional offenses require a mandatory court appearance with fines determined by the Court

Boulder, CO

New Buildings over 10,000 sq ft & Existing Buildings over 20,000 sq ft are required.

Benchmarking filing is due June 1st of each year.

Violations:
Owners of affected buildings are required to rate and report building energy data, and complete efficiency actions by the deadlines posted (see above). Failure to do so can result in fines of $0.0025 per square foot – up to $1,000 per day of non-compliance.

Any Tenant of an owner subject to the provisions of this chapter shall, within 30 days of a request, provide the owner with any information required for compliance that cannot otherwise be acquired by the owner.

Denver, CO

Commercial and Residential buildings over 25,000 sq ft are required.

Benchmarking filing is due June 1st of each year.

Energize Denver Ordinance (EDO) will penalize those who do not comply with a fine of $2000 Annually for Benchmarking, failure to correct errors, knowingly withholding or inaccurate information

Fort Collins, CO

Covered buildings are commercial and multifamily buildings with 5,000 square feet or more of gross floor area

Annual reporting deadline is June 1 each year. Covered buildings in the 5,000‑50,000 sq ft range get one 12‑month grace period for their first reporting year. After that, no more grace periods

Fine amount: up to $3,000 per year of noncompliance for each covered building.

Florida

Orlando, FL (BEWES)

Any city-owned building above 10,000 gross square feet and any commercial or multifamily building above 50,000 gross square feet is required.

Benchmarking filing is due May 1st of each year.

Those who have not complied by the deadline will be notified by the city and identified as non-compliant in an annual report and Orlando’s public benchmarking map.  Buildings that receive a score below 50 are required to perform an energy audit or a retro-commissioning service to better understand their building performance and cost saving opportunities, minimize our energy waste, and maximize cost savings. 

Miami, FL

Buildings 20,000 square feet or greater of floor space and 5 or more units are required.

Benchmarking filing is due either June 30th or October 1st of each year depending on the square footage of the building.

The fines for non-compliance are $250 per day for the first offense & $500 per day for a repeat violation.

GEORGIA

Atlanta, GA

Municipal buildings above 10,000 square feet, and commercial and residential buildings above 25,000 square feet are required.

Benchmarking filing is due July 1st of Each Year.

Written warning after 30 days, $1,000 fine if compliance is not reached within another 30 days.  Additional $1,000 fine each year going forward for non compliance.

HAWAII

Honolulu

Commercial and multi‑family buildings on Oʻahu that are 25,000 square feet or larger in gross floor area.

The June 30, 2025 reporting deadline has been extended to September 30, 2025.

If benchmarking information is not submitted by the deadline A civil penalty not to exceed US$1,000. Plus a further penalty of US$100 per day for each day the department is not notified / the information is not submitted

ILLINOIS

Chicago, IL

Any building 50,000 square feet and above is required.

Benchmarking filing is due June 1st of each year.

The Chicago Energy Benchmarking Ordinance (EUBO) fines building owners $100 for the first violation and up to $25 for each additional day the violation continues. This means that building owners could be fined up to $9,200 per year for each building out of compliance.

Data Verification by licensed authorized third party required once every three years.

Evanston, IL

Public city building exceeding 10,000 square feet & Commercial or multifamily building of at least 20,000 square feet are required.

Benchmarking filing is due by June 30th of each year.

Buildings failing to adhere to City of Evanston benchmarking ordinance by the specified deadline will be charged $100 per month of non-compliance.

Oak Park, IL

The ordinance applies to “covered properties” of 10,000 square feet or larger.

The deadline to report the previous year’s data is December 31. For example, data for the 2024 calendar year is due by December 31, 2025

INDIANA

Indianapolis, IN

City‑owned / municipal buildings that are 25,000 square feet or larger. Non‑city: ≥ 50,000 sq ft (ongoing)

The reporting must be done annually via EPA’s Energy Star Portfolio Manager (or equivalent) by June 1 each year.

The penalty schedule for noncompliance has been publicly reported as $100 in the first year, and $250 per year thereafter.

IOWA

Des Moines, IA

Building Energy Benchmarking Ordinance (Ord. 35,154)

Covered buildings include commercial, multifamily, and municipal (city‑owned) buildings with a gross floor area ≥ 25,000 square feet.

July 1st annual deadline (not definitive)

Late submissions (more than 30 days) will be charged a $50 late fee. Failure to remediate non-compliance within 30 days will result in a $300 violation fee. Subsequent violations will be charged a $500 fee. (not definitive)

Louisiana

New Orleans, LA

Building Energy Benchmarking Ordinance (Ord. 35,154)

Buildings >20,000 square feet

Properties with a combined building area of 50,000 square feet and above must comply beginning January 1, 2026.

Properties with a combined building area of 20,000 square feet and above must comply beginning January 1, 2027.

Properties must submit benchmarking information to the City by May 31 each year.

Failure to comply with the benchmarking requirement may result in fines between $1,000 and $3,000. Penalties will be waived in the first year a property is required to comply.

MAINE

Portland, ME

Municipal buildings (city‑owned / public) ≥ 5,000 sq ft gross floor area

Private commercial / multifamily / large private buildings ≥ 20,000 sq ft gross floor area

The annual reporting deadline is May 1

The fine for non‑compliance is set at $20 per day for buildings that fail to file the required report by the deadline.

MASSACHUSETTS

Massachusetts Statewide Energy Benchmarking

Building with at least 20,000 square feet of gross floor area

Reporting by utilities for buildings usage data By June 30, 2025, for the previous calendar year (i.e. 2024), and each year afterward.

Publication of energy data by DOER: must publish the building‑level energy usage data (and database) annually, by October 31 each year.

The DOER may establish civil penalties for failure to comply. The statute caps such civil penalties at $150 per day

Boston, MA (BERDO 2.0)

Buildings 20,000 square feet or larger or have 15 or more units are required.

Benchmarking filing is due May 15th of each year- Subjected to fines of $150-$300 per day for buildings failure to benchmark depending on their size. 

New and separate fines for failure to meet the emissions performance standards could be up to $1,000 per day. Fines for inaccurate reporting will range between $1,000 and $5,000.

Qualified Third-Party Data Verification required once every 5 years.

Cambridge, MA

Any parcel of land which contains buildings that total greater than 25,000 sq ft or more than 50 residential units remains subject to the benchmarking requirements of the ordinance. 

Compliance due date May 1st of Each Year.

Written warning after 30 days, $1,000 fine if compliance is not reached within another 30 days.  Additional $1,000 fine each year going forward for non compliance.

Beginning in 2026, submitted data will need to be verified to be considered compliant and emissions limits, performance standards will be in effect in coming years. Initial violation will result in a warning, subsequent violations will receive fines of $300 per day.

CHELSEA, MA

Buildings with 20,000 square feet of gross floor area (GFA) or more or residential buildings with 20 units or more to report energy use data.

The first reporting deadline is June 30 of each year.

LEXINGTON, MA

Commercial and multifamily buildings with one or more buildings over 25,000 square feet, as well as all town-owned or leased buildings.

The annual reporting deadline is May 15th for the previous calendar year’s data.

Under LBER regulations, some published commentary indicates fines as high as $150 per building, per day for non‑reporting past the deadline.

MARYLAND

Maryland Statewide Benchmarking Law

Applies to buildings in the state 35,000 square feet or larger (excluding parking garage area)

Certain types of buildings are exempt: historic buildings; public and nonpublic elementary and secondary schools; manufacturing buildings; agricultural buildings; federal buildings.

Due June 1 of each year, starting in 2026, using the data for the previous calendar year.

Licensed third party data verification due once every 5 years.

Emissions limits beginning in future years.

Montgomery County, MD

Buildings 25,000 square feet and above are required. 

Benchmarking filing is due June 1st of each year.

The Benchmarking Law is enforceable under Method 2 regulations (including fines for noncompliance), and any violation of the law is a Class A violation. DEP will send out Notice of Violation to any building owner of a covered building who does not comply with the Law.

MICHIGAN

Ann Arbor, MI

Buildings and campuses of buildings greater than 20,000 square feet are required to submit a benchmarking report.

Benchmarking filing is due June 1st of each year.

$500.00 for a first offense, and $1,000.00 for each additional or subsequent offense, plus the costs of prosecution including court costs. Knowingly submitting a false Benchmarking Report or submitting it with reckless disregard for the truth and accuracy of it and/or the data on which it is based is a civil infraction punishable by a fine of $500.00 plus the costs of prosecution including court costs. 

Detroit, MI

Buildings between 25,000 and 100,000 Gross square feet.

Due June 1, of each reporting year

MINNESOTA

Minnesota Statewide Benchmarking

A covered property is defined as a building (or combined buildings) with 50,000 or more gross square feet served by an investor‑owned utility (in certain counties) or by a municipal utility in a city over 50,000 population.

The law divides properties into two classes:
• Class 1 = 100,000+ sq ft
• Class 2 = 50,000 to 99,999 sq ft 

Each year by March 1, the commissioner must notify owners of covered properties of their obligation to benchmark by June 1.

Each year by December 1, the commissioner must post summary statistics and individual building data (for properties in compliance) for the prior calendar year.

The statute provides that if an owner fails to comply with the benchmarking requirements, the commissioner must notify the owner by June 15 of non‑compliance. The owner then has until July 15 to comply.

The owner may request an extension (to August 15). If the owner still fails to comply (i.e. by August 15), the commissioner may impose a civil fine of $1,000 on the owner

Edina, MN

All commercial and multifamily buildings in Edina of 25,000 square feet or larger.

Existing buildings 25,000-49,999 square feet must comply with Edina’s Efficient Buildings Ordinance to annually benchmark and report their energy and water use by June 1 each year. 

Existing buildings 50,000 square feet or larger must comply with the State of Minnesota’s Large Building Benchmarking Program to annually benchmark and report their energy use

Minneapolis, MN

Commercial and Residential buildings 50,000 square feet and above are required.

Benchmarking filing is due June 1st of each year.

Buildings will receive initial $200 violation for non-compliance by deadline, then from there the fines will be doubled for each deadline missed.  If you miss all deadlines to comply, the total will be added to your property taxes at the end of the year.

Missouri

Clayton, MO

City‑owned (or partially city‑owned) buildings of 10,000 gross square feet or more. Non‑city‑owned commercial / multifamily / condominium properties whose combined floor area is 100,000 gross square feet or more

First submission due April 1, 2027 for private buildings, then annually by April 1 each year.

St. Louis, MO

Any building 50,000 square feet or over is required.

Benchmarking filing is due May 1st of each year.

Failure to benchmark shall constitute an offense and shall be punishable, upon conviction, by a fine of not less than $50.00 and not more than $200.00. For any continuing violation of this article, each day of the violation shall be considered a separate offense. Buildings not in compliance with the ordinance would NOT be eligible for the issuance of new residential or commercial occupancy permits.

Kansas City, MO

Compliance for the Energy Empowerment Ordinance requires owners of buildings 50,000 SQFT or greater located in the Kansas City, Missouri municipality to submit energy and water consumption to the City on an annual basis.

All applicable buildings must comply by May 1st of each year.

Kansas City can impose a fine between $50 and $500, which accumulates every day it’s not resolved until it reaches a maximum of $2,000.

NEVADA

Reno, NV

City‑owned (municipal) buildings ≥ 10,000 sq ft,  State agency or local agency properties ≥ 30,000 sq ft where the agency pays energy or water bills, Private commercial and multifamily buildings ≥ 30,000 sq ft

Annual reports are due April 1 each year

If noncompliance continues for 30 days after the warning, a fine of $100 will be assessed to the building owner.

NEW JERSEY

New Jersey

Every commercial building over 25,000 square feet in the state to benchmark energy and water use using the U.S. Environmental Protection Agency’s Portfolio Manager tool, as required by the New Jersey Clean Energy Act.

Benchmarking filing is due June 1st of each year

NEW YORK

Bedford, NY

The Town of Bedford has adopted a policy of benchmarking its own buildings. Town‐owned buildings (over 1,000 square feet) are required to report annual energy use

Every June 1 for commercial, residential, and municipal buildings greater than 50,000 square feet. 

It further says that violation shall be an unclassified misdemeanor, with minimum and maximum fines possible (“a minimum fine of $250 and a maximum fine of $5,000, or imprisonment not exceeding six (6) months, or both such fine and imprisonment”).

New York City, NY

Buildings 25,000 square feet and above are required. 

Benchmarking filing is due June 1st of each year, followed by subsequent energy letter grade required to be posted due between October of that same year if applicable.

A $500 fine per quarter in violations; also a $0.50 per square foot the size of the building per month for market rate properties who do not file their emissions.

Local Law 97 associated law is a Carbon Emissions limit followed by subsequent penalties in effect for certain applicable buildings *see our carbon Footprint analysis page for more information

OHIO

Columbus, OH

Commercial and multifamily building owners (or managers) of buildings 50,000 square feet or larger must benchmark electricity, gas, and water usage for the entire building. 

City‑owned buildings 25,000 square feet or larger are required to begin benchmarking.

The annual reporting deadline is June 1 of each year, for the prior calendar year’s data.

For the first violation, the civil penalty is up to $100.  For a second violation within a 12‑month period: $250. For a third and subsequent violations (within 12 months): $500 each

OREGON

Portland, OR

Portland’s Commercial Building Energy Reporting policy applies to commercial buildings 20,000 square feet or larger.

Reporting is annual, with a due date of April 22 each year. 

For Portland, non‑compliance can lead to fines of up to $500 every 90 days for buildings failing to report

PENNSYLVANIA

Philadelphia, PA

Buildings 25,000 square feet and above are required. 

Benchmarking filing is due June 30th of each year.

A fine of two thousand dollars ($2,000) for non-compliance. Each day that a building owner fails to file a required report 30 days after the deadline shall constitute a separate violation, subject to a fine of five hundred dollars ($500) for each day going forward.

Pittsburgh, PA

Buildings 50,000 square feet and above are required. 

Benchmarking filing is due June 1st of each year.

Any Covered Building Owner or City Facility operator which fails to comply with the benchmarking requirements will be publicly listed as non-compliant on the online platform, described as “eligible and non-participating.” 

RHODE ISLAND

Providence, RI

Private covered properties 10,000 square feet or greater.

Annually by May 15

Property owners who fail to report energy usage by the required deadlines could face civil fines up to $5,000. Some sources report that First violation is written warning and Second and subsequent violations are:

Buildings ≥ 50,000 sq ft – $40 per day to a maximum of $4,000 per year

Buildings ≥ 20,000 sq ft – $30 per day to a maximum of $3,000 per year

UTAH

Salt Lake City, UT

Salt Lake City’s Energy Benchmarking and Transparency Ordinance requires all commercial buildings above 25,000 sf to benchmark and report their energy consumption

May 1st annual deadline

The fines for non-compliance are up to $1000 per year.

TEXAS

Austin, TX

Commercial, multifamily, or residential buildings above 10,000 square feet (only if the building receives energy from Austin Energy are they required).

Benchmarking filing is due June 1st of each year.

Noncompliance for commercial, multifamily, and residential buildings can result in fines from $500 to $2,000.

VERMONT

Burlington, VT

A commercial property (not residential) that is metered or sub-metered for thermal loads and has space‑conditioned square footage between 10,000 and 49,999 sq ft

Data (monthly + annual) must be submitted to the Burlington Department of Permitting & Inspections (DPI) by May 15, 2026 (for the first full year of benchmarking).

Starting January 1, 2027, benchmarking and reporting must continue for each subsequent 12‑month period (every year) until or unless the ordinance is amended

Civil penalties up to US$500 per violation for noncompliance: either for failure to begin benchmarking within the required time or failure to submit required data to DPI

Washington, D.C.

Washington, DC

Buildings 25,000 square feet and above are required. 

Benchmarking filing is due by April 1st of each year. 

Failure to do so can result in fines of up to $100 per day of non-compliance.

Data Verification by a licensed authorized third party is required once every three years 

Washington

Washington Statewide Benchmarking

Clean Building performance standards - Benchmarking required for large commercial buildings statewide.

Broader than pure benchmarking — your submission includes benchmarking, energy management plans, O&M plans, and the building’s performance relative to its energy use intensity target

Tier 1 Covered Buildings: non‑residential, hotel/motel/dormitory, with gross floor area exceeding 50,000 sq ft

June 1, 2026 – buildings over 220,000 sq. ft. must comply.

June 1, 2027 – buildings 90,001 – 220,000 sq. ft. must comply.

June 1, 2028 – buildings 50,001 – 90,000 sq. ft. must comply. 

Tier 2 Covered Buildings: smaller buildings 20,000 to 50,000 sq ft and certain multifamily buildings.

July 1, 2027 – All Tier 2 buildings (commercial 20,001–50,000 sq. ft. and multifamily residential over 20,000 sq. ft.) must report benchmarking, EMP, and O&M. 

Tier 1 buildings: Fines can go up to $5,000 annually, or as much as $1 per square foot per year.

Tier 2 buildings (5-year cycles): Penalties may be up to $0.30 per square foot for each 5-year compliance period.

Seattle, WA

Commercial and Multifamily buildings 20,000 square feet and above are required.

Benchmarking filing is due June 1st of each year.

Fines for properties between 20,000 and 50,000 square feet will be $2,000.  Fines for properties greater than 50,000 square feet will be $4,000.

WISCONSIN

Madison, WI

Benchmarking (annual energy use reporting) for all commercial buildings  25,000 sq ft or more. building “tune‑ups” every 4 years for buildings 50,000 sq ft or more.

The reporting deadline for benchmarking is June 30

Failure to comply with benchmarking  requirement: $1,000 per every 90 days of noncompliance.

Milwaukee, WI

Effective:; first reporting due Sep 30, 2025 (2024 energy data)

Who’s covered: Public buildings ≥10,000 sq ft; commercial ≥50,000 sq ft

What’s required: Annual benchmarking & data sharing with the City

Failure to comply (not submitting required benchmarking data): $1,000 for each 90‑day period of noncompliance (i.e., per 90 days while still noncompliant)