US building performance standards
US building performance standards: 2030 is the cliff.
Benchmarking laws asked owners to report. Building performance standards set a limit and charge for missing it. New York and Boston limits already apply, and from Washington State to Maryland the first penalties land between 2026 and 2031. The data you collect now is the record you will be measured against.
When penalties start
Most first deadlines fall between now and 2031.
Each program phases in by building size, so the largest buildings go first. These are the dates that matter for a commercial portfolio.
Timeline
US building performance standards, year by year
- 2024 to 2025
- NYC Local Law 97 limits apply from 2024. Boston BERDO limits apply to the largest buildings from 2025, assessed in 2026.
- 2026
- Washington State Clean Buildings: first Tier 1 deadline on June 1, for buildings over 220,000 sq ft. Washington, DC: the first BEPS cycle ends on December 31.
- 2027
- Washington State: Tier 1 buildings of 90,001 to 220,000 sq ft, and the first Tier 2 reports. Seattle: first emissions reports for the largest buildings, due October 1.
- 2028
- Washington State: Tier 1 buildings of 50,001 to 90,000 sq ft.
- 2029
- Washington, DC: the second BEPS cycle starts for buildings of 25,000 sq ft and up. Denver: the city says no penalties before late 2029.
- 2030
- New York and Boston limits tighten, and smaller Boston buildings join. Colorado performance penalties can start. Maryland's first standard: 20% below 2025 direct emissions. Denver's final target year.
- 2031
- Seattle: first emissions targets for buildings over 220,000 sq ft, with smaller buildings following through 2035.
- 2040 to 2050
- Maryland: net zero direct emissions in 2040. Seattle: net zero between 2041 and 2050, by size. New York and Boston: net zero in 2050.
Program by program
Six programs, three different yardsticks.
Some programs score energy use, some score emissions, and DC starts from the ENERGY STAR score. All of them run on ENERGY STAR Portfolio Manager data.
Washington, DC
Building Energy Performance Standards
- Covered
- Private buildings of 50,000 sq ft and up in the first cycle, 25,000 sq ft and up from the second
- Measures
- ENERGY STAR score. Buildings below the standard can comply by cutting normalized site energy use by more than 20%
- Key dates
- First cycle ends December 31, 2026. Second cycle moved to January 1, 2029 by a 2026 emergency act
- Penalty
- Alternative compliance payment scaled to floor area, capped at $7.5 million per building and reduced for partial progress
Washington State
Clean Buildings Performance Standard
- Covered
- Tier 1: non-residential, hotel and dormitory space over 50,000 sq ft. Tier 2: 20,001 to 50,000 sq ft, plus multifamily
- Measures
- Site energy use intensity target by building type, plus an energy management plan and an operations and maintenance program
- Key dates
- Tier 1 due June 1, 2026, 2027 or 2028 by size. Tier 2 reports due July 1, 2027
- Penalty
- Up to $5,000 plus $1.50 per sq ft of gross floor area
Denver, Colorado
Energize Denver
- Covered
- Buildings of 25,000 sq ft and up
- Measures
- Weather-normalized site energy use intensity, set for 30% savings across covered buildings by 2030, and never more than 42% for one building
- Key dates
- Targets for 2025, 2027 and 2030, or an opt-in timeline with targets in 2028 and 2032
- Penalty
- Charged per kBtu above target. The city halved the rates in 2026 and says none will be levied before late 2029
Colorado
Building Performance Colorado
- Covered
- Most commercial, multifamily and public buildings of 50,000 sq ft and up, about 8,300 buildings
- Measures
- Building performance against a goal of 7% lower building emissions by 2026 and 20% by 2030, compared with 2021. 2040 standards still to be set
- Key dates
- Benchmarking report due November 1 each year. Performance penalties from January 1, 2030
- Penalty
- Up to $2,300 per 30 days, and $5,800 for a repeat violation. Energize Denver buildings are deemed compliant
Seattle, Washington
Building Emissions Performance Standard
- Covered
- Non-residential and multifamily buildings over 20,000 sq ft
- Measures
- Greenhouse gas intensity in kgCO2e per sq ft per year, verified every five years by a qualified person
- Key dates
- First reports from October 1, 2027 for the largest buildings. First targets from 2031 to 2035 by size, net zero from 2041 to 2050
- Penalty
- Up to $10 per sq ft for non-residential buildings that miss a target. Alternative compliance at $190 per ton for 2031 to 2035
Maryland
Building Energy Performance Standards
- Covered
- Commercial and multifamily buildings of 35,000 sq ft and up. Montgomery County may run its own program
- Measures
- Net direct greenhouse gas emissions: 20% below 2025 by 2030, net zero by 2040. Benchmarking every June 1 in Portfolio Manager
- Key dates
- Third-party verified data for 2025, 2030, 2035 and 2040. Bills to repeal or delay the program stalled in 2026
- Penalty
- Alternative compliance fee of $230 per ton of excess emissions in 2030, rising $4 a year to $270 in 2040, in 2020 dollars
More are coming. Cambridge, Massachusetts has emissions limits for large non-residential buildings from 2026, Montgomery County, Maryland sets energy targets from 2028, and Oregon's first deadlines arrive in 2028. In California, the Energy Commission has recommended a statewide standard on top of AB 802 benchmarking, though it is not yet law. Programs change often: Washington, DC and Denver both moved their timelines in the last two years. Sources: each program's official city or state pages, checked October 2026.
Rhino's role
Start collecting real data now.
Every one of these programs compares a building against its own past or against a limit, using meter data. The years before the first deadline are when the baseline gets written and when there is still time to cut.
01
A baseline you can defend
Maryland measures against 2025, Colorado against 2021, and verifiers in Boston, Seattle and Maryland check the numbers. Rhino reads every meter automatically, electricity, gas, water and heat, so the record is measured, complete and traceable to timestamped readings.
02
One dataset for every city
Every program here runs on ENERGY STAR Portfolio Manager. Export monthly totals per meter for each building, wherever it sits, or send the data to Measurabl and your own tools through the Rhino API.
03
Find the cuts before the deadline
15-minute data shows where a building wastes energy: after-hours HVAC, a plant that never switches off, a tenant whose load doubled. Those are the cheapest tons and kBtu to remove, and the ones a yearly bill never shows.
What Rhino covers
All utilities
Electricity, gas, water, heat, including tenant submeters. Every meter a performance standard counts, in one platform.
15 min
Default data granularity, stored from day one. Continuous metering, not a once-a-year total.
2030
The year most programs bite. The data that decides it is being collected now.
Common questions
Building performance standards, answered.
A building performance standard, or BPS, is a law that requires existing buildings to meet a set level of energy or emissions performance, usually tightening over time. Unlike a benchmarking law, which only requires reporting, a BPS sets a limit and attaches a penalty or an alternative compliance payment to missing it.
Adopted programs include New York City (Local Law 97), Boston (BERDO), Washington, DC, Washington State, Seattle, Denver, Colorado and Maryland, along with Cambridge, Massachusetts, Montgomery County, Maryland and Oregon. Thresholds, metrics and deadlines differ for each.
It depends on the program and the building size. New York and Boston limits already apply. Washington State's first deadline was June 1, 2026. Washington, DC starts its second cycle in 2029, Colorado performance penalties can start in 2030, Maryland's first standard applies in 2030, and Seattle's first targets arrive in 2031.
One of three things. Energy use intensity, the energy used per square foot, in Washington State and Denver. Greenhouse gas intensity or total emissions in New York, Boston, Seattle and Maryland. The ENERGY STAR score in Washington, DC. All of them rely on annual energy data reported through ENERGY STAR Portfolio Manager.
A payment that counts as compliance for a building that misses its standard. Several programs set it per ton of excess emissions: $268 in New York, $234 in Boston, $190 in Seattle for 2031 to 2035, and $230 rising to $270 in Maryland. Washington, DC scales its payment to floor area, capped at $7.5 million per building.
Start with complete, measured data for every utility in every covered building, so you know where each one stands against its future limit. Then find the cheapest reductions, such as after-hours and scheduling waste, before planning capital projects. Programs often set baselines in early years, so data gaps today become problems later.
Know where every building stands before 2030.
Rhino connects to the meters you already have, in every city in your portfolio, and shows what each building consumes across all utilities, every 15 minutes.
Further reading
From the Rhino blog.
