NYC Local Law 97 Compliance Deadlines: A Building Owner’s Timeline

If you own or manage a building larger than 25,000 square feet in New York City, Local Law 97 should be at the top of your priority list right now. The challenge is that LL97 doesn’t exist in isolation. In essence, it overlaps with several other laws, each with its own deadlines. Keeping track of all of them can get confusing fast, and missing even one deadline can lead to financial penalties.

Local Law 97 of 2019 (“LL97”), as amended, is designed to greatly reduce building operational carbon emissions toward a goal of net zero by 2050. To make things easier, here’s a clear timeline of the key LL97 milestones from 2024 through 2050, along with the related deadlines for LL84, LL87, and LL88 that play a role in your overall emissions compliance strategy.

2024 – 2025: Multiple Extensions

When emissions limits officially went into effect for a single building over 25,000 square feet or, over 50,000 square feet for multiple buildings that are either on a single lot or governed by the same board of managers, the Department of Buildings allowed multiple extensions during 2024 and 2025. See the new filing deadlines below as well as the filing deadlines for other Local Laws.

Annual: Benchmarking

LL84 / LL33 is due annually on May 1.  This is where you benchmark all the energy usage in your building in Energy Star Portfolio Manager. The result of this effort is your building’s Energy Score, which must be posted near the entry of the building by October 31 of the same year. If any May 1 deadline is missed, there are other chances to catch up quarterly, on August 1, November 1, and February 1.

Every Decade: Energy Audit and Retro-commissioning

LL87 consists of filing both an energy audit and a retro-commissioning report on December 31, every ten years. The year the LL87 is due depends on the last digit of the building’s BBL.  For instance, if the BBL of the building ends in “8”, the LL87 filing is due 2028, 2038, 2048, etc. This is for every digit between 0-9. If the BBL ends in “5”, rather than being due December 31, 2025, it was due on March 31, 2026, due to managing all the filings occurring during this time. This was the only year where LL87 had a delayed filing deadline.

One Time: Lighting and Submetering

LL88 requires covered buildings to complete lighting system upgrades and install sub-meters. After multiple extensions, building owners who submitted Compliance Plans by December 31, 2025 were required to submit compliance documentation to the NYC Department of Buildings confirming that required upgrades were completed in accordance with the law by May 1, 2026. For buildings that do not perform these upgrades and / or have not filed, annual fines will accrue until the upgrades are made and the paperwork is filed. The fines are $1,500 annually for lighting and $1,500 annually for submetering plus $500 for each covered space.

2025, 2026, 2027, 2035: Article 320 & 321

You must determine whether your building falls under Article 320 or Article 321, and therefore your compliance path, to see when your LL97 filing is due. The specific pathway depends on the building’s characteristics, with affordable housing being a primary delineator.  Check with the DOB’s Article 320 Info Guide and Article 321 Info Guide to determine the appropriate pathway for your building.

The first annual LL97 emissions reports for the 2024 compliance year were due in 2025. According to the Department of Buildings, 93% of buildings that were required to file for LL97 in 2025 did! 

If your building was to file LL97 by May 1, 2026, and did not file, you may apply for an extension on or before June 30, 2026. Then the building will become eligible for a grace period which closes on August 29, 2026.

Residential buildings with at least one rent-regulated unit, but fewer than 35% rent-regulated units are required to comply with LL97 by 2027. Their first emissions report will be due on May 1, 2027, covering 2026 data.

The DOB is more interested in compliance with the law than in the actual fines, however, they will take enforcement action for non-compliance with these laws.

Certain types of affordable housing not subject to Article 321, will not need to file until 2035.

2030: Stricter Limits Take Effect

The 2030–2034 compliance period brings much tighter emissions limits with roughly 50% stricter than the current ones. City projections show that around 63% of buildings will exceed these new limits without major upgrades.

At the same time, the electricity carbon factor will decrease as New York’s grid becomes cleaner. This creates an opportunity: buildings that switch to electric systems (like heating and hot water) can benefit more in terms of compliance. Even if your building is fine today, that doesn’t guarantee you’ll meet the 2030 limits. Planning ahead now can save you from rushed and expensive upgrades later.

2050: Net Zero Goal

By 2050, all covered buildings must reach net-zero carbon emissions. This is the long-term goal of the Climate Mobilization Act. Buildings that start early will have the advantage of spreading costs over time and making gradual improvements instead of facing last-minute pressure.

Smart building owners don’t treat these laws separately. They combine them into one coordinated plan to reduce costs and avoid doing the same work twice.

Don’t Wait to Start

Proactive planning gives building owners more flexibility when budgeting and prioritizing energy upgrades tied to LL97 compliance. Starting early can help reduce project bottlenecks, improve financing opportunities, and allow more time to implement long-term efficiency improvements.

For many properties, the biggest challenge is not knowing how future compliance requirements may impact operational costs, capital planning, and building performance.

Call (914) 304-4033 or request more information today.