SUMMARY

At Donnelly Mechanical, we see Local Law 97 compliance succeed when building operations, reporting inputs, and HVAC performance work together year-round. In 2026, reporting rules tighten further, and the Department of Buildings continues to expand how emissions limits are determined and submitted. This blog breaks Local Law 97 into plain language, highlights the 2026 dates to calendar, explains what changes in reporting, and outlines practical HVAC steps that typically reduce risk before deadlines force rushed decisions.

 

Start here: what Local Law 97 is really measuring

For facility managers, the main point is simple. HVAC affects emissions because HVAC drives energy use. If runtime is higher than it needs to be, if controls are not aligned with occupancy, or if systems are fighting each other, energy consumption climbs and emissions often follow.

A quick glossary:

• Emissions limit: the cap your building is allowed for that year (based on building characteristics and rules).
• tCO2e: “metric tons of carbon dioxide equivalent,” a standard way to measure greenhouse gas emissions.
• ESPM: U.S. Environmental Protection Agency (EPA) ENERGY STAR Portfolio Manager, the tool used to track building energy data and benchmarking.
• BEAM: Building Energy Analysis Manager, the NYC portal used to submit Local Law 97 compliance reports.
• DOB NOW: the NYC Department of Buildings online system used for certain filings and fee payment steps tied to the reporting process.

2026 compliance dates to put on the calendar now

You do not need to memorize the law to manage it. You do need to track the dates that drive work back into Q1 planning.

March 31, 2026: Local Law 87 Energy Efficiency Report deadline extension (if it applies)

The New York City Department of Buildings issued a service notice extending the Energy Efficiency Report (EER) deadline under Local Law 87 to March 31st, 2026 for owners required to demonstrate compliance in the 2025 filing year. The notice states the extension is for that filing year only. 

Why it matters: It occurs immediately before the May 1st reporting deadline, when demand increases sharply. If your building is on that schedule, allocate resources in advance.

March 30th, 2026: anticipated enforcement of the 2025 NYC Energy Conservation Code

DOB’s service notice states the anticipated enforcement date of the 2025 NYC Energy Conservation Code is March 30th, 2026, and that DOB will continue enforcing the 2020 code until updated compliance software is available. 

Why it matters: If you are planning HVAC work that triggers filings (alterations, equipment replacement, permitted controls work), code timing can affect design assumptions and documentation.

May 1st, 2026: Local Law 97 annual emissions report due + benchmarking cycle

DOB guidance for Local Law 97 reporting under Article 320 describes annual compliance reporting due by May 1st, covering the prior calendar year, and it also explains the late filing penalty approach.
Benchmarking under Local Law 84 is also tied to the May 1st cycle, with DOB requiring covered buildings to benchmark energy and water use prior to May 1st each year.

 

What changes in 2026 for Local Law 97 reporting

2026 requires ESPM property types for emissions reporting

DOB is clear that, beginning in 2026, all owners must report emissions using ESPM property types.

This change is especially important for:

• Mixed-use buildings, where floor-area splits can be difficult to define accurately
• Buildings that previously relied on “good enough” classifications for earlier reporting years
  Teams that have not recently reviewed property types and space allocations

If your building is still using an older setup, 2026 is the year to validate it, because the data you enter will directly influence how emissions limits are calculated and applied.

 

How Local Law 97 reporting works

DOB’s published process guides show Local Law 97 reporting is spread across connected systems. 

Here is the simplest way to think about it:

1. Pay the fee through DOB NOW (this step ties your building and key contacts into the process). 
2. Confirm energy data in EPA ENERGY STAR Portfolio Manager (ESPM) (meters, fuels, building details, property types).
3. Submit the compliance report through BEAM, which is DOB’s reporting portal for Local Law 97 compliance submissions. 

What is BEAM: BEAM stands for Building Energy Analysis Manager. DOB identifies BEAM as the reporting portal for Local Law 97 compliance submissions, including annual reporting under Article 320. 

Key takeaway: Compliance is not a one-week push. It depends on accurate metering, a clean portfolio manager configuration, strong documentation, and clear ownership across the facility and admin team.

 

Penalties: why HVAC efficiency shows up on the balance sheet

DOB’s violations guidance spells out two penalty formulas that facility teams should understand because they turn operational performance into direct cost. 

1) Late or missing annual emissions report

Penalty = (Floor Area × $0.50) per month 

Example: A 200,000 square foot building that files 2 months late

• 200,000 × $0.50 = $100,000 per month
• $100,000 × 2 = $200,000 penalty

2) Exceeding the annual emissions limit

Penalty = ((Actual Emissions – Emissions Limit) × $268) per year 

Example: A building that exceeds the limit by 120 tCO2e

• 120 × $268 = $32,160 per year

These numbers matter because exceedance penalties apply each year the building remains over the limit. HVAC efficiency affects this because HVAC runtime, control strategy, heating performance, ventilation settings, and simultaneous heating and cooling behavior can materially shift energy use and emissions.

HVAC efficiency moves that typically reduce Local Law 97 exposure

There is no single fix that works for every NYC building. In our experience, the most reliable improvements fall into a few categories that reduce waste and improve controllability.

1) Controls optimization and schedule discipline

One of the lowest-disruption ways to reduce waste is a focused review of how the building automation system is actually operating. Schedules drift. Overrides get applied and never removed. Setpoints stop matching real occupancy patterns. A targeted controls review can reduce unnecessary runtime and stabilize comfort.

WHY BUILDING MANAGEMENT SYSTEMS ARE IMPORTANT FOR HVAC

2) Functional testing with a retro-commissioning mindset

You do not always need a full program to benefit from the approach. The goal is to confirm systems are operating as intended and to catch “normal failures” that quietly increase runtime, such as leaking valves, stuck dampers, poor economizer function, and sensors out of calibration.

CONDUCTING HVAC SYSTEM ANALYSIS: A COMPREHENSIVE GUIDE

3) Preventive maintenance that keeps performance from slipping

Maintenance is not only a reliability strategy. It is often an efficiency strategy. Dirty coils, clogged filters, belt issues, stuck dampers, failing valves, and short cycling can drive longer runtimes and higher energy use.

4) A 2 to 4 year HVAC roadmap tied to compliance timing

A staged plan is usually more realistic than reactive decisions. Optimize what you have now, target repairs that deliver fast wins, and schedule larger upgrades so you are not forced into rushed scope later, especially with 2025 NYC Energy Conservation Code enforcement timing in the mix. 

HOW THE INTERNET OF THINGS (IOT) WILL SHAPE THE HVAC INDUSTRY IN 2025

 

A practical 2026 action plan for NYC facility managers

January to March: clean up reporting inputs

Confirm portfolio manager structure, property types, meter completeness, and building emissions early so May does not become rework season. 

Q1 to Q2: run an HVAC efficiency risk review

Focus on runtime drivers, ventilation schedules, control point drift, and chronic comfort complaints. Document what can be fixed operationally versus what needs a capital plan.

Before peak season: implement fast wins

Control changes, tune-ups, scheduling corrections, and targeted repairs often create measurable reductions faster than major replacement projects.

2026 project planning: account for NYC Energy Code timing

If scope involves DOB filings, plan around the anticipated March 30th, 2026 enforcement date for the 2025 NYC Energy Conservation Code. 

Bring in technical support before decisions are finalized

For buildings trending near the Local Law 97 annual emissions cap in the current compliance period, early guidance helps avoid rework and improves the timing of capital improvements.

 

How Donnelly Mechanical supports NYC facility teams

At Donnelly Mechanical, our team supports NYC building owners and facility managers with commercial HVAC service and maintenance, construction, and energy solutions. We help teams connect day-to-day system performance to long-term efficiency and compliance goals.

If you want to get ahead of 2026 compliance, contact our team to schedule an HVAC efficiency and controls review. We will help you identify practical operational wins, prioritize repairs, and build an HVAC roadmap aligned with NYC reporting deadlines and code timing.

Frequently Asked Questions