NYC Local Law 84: What You Need to File by May 1

What Is Local Law 84?

NYC Local Law 84 of 2009 (LL84) requires most buildings 25,000 square feet or larger to report annual energy and water consumption to the City of New York. Data must be submitted through ENERGY STAR Portfolio Manager — the EPA's free web-based benchmarking platform — by May 1 each year.

Filed data covers the prior calendar year (e.g., the May 1, 2026 filing covers calendar year 2025). After filing, the city publicly discloses all reported data on the NYC Open Data portal, typically 6–9 months after the deadline.

Who Must File?

• Private buildings with 25,000 sq ft or more of gross floor area
• NYC-owned buildings with 10,000 sq ft or more
• Multiple buildings on the same tax lot totaling 50,000 sq ft or more combined

What Must Be Reported?

The following must be entered into ENERGY STAR Portfolio Manager for the prior calendar year:

• Annual electricity consumption (kWh)
• Annual natural gas consumption (therms)
• Annual fuel oil consumption (gallons, by grade)
• Annual district steam consumption (MMBtu)
• Annual water consumption (required under Local Law 85)
• Gross Floor Area by occupancy type
• Occupancy details (hours, number of workers, number of units)

Once this data is in ESPM and the building meets the occupancy data requirements, ESPM automatically calculates the ENERGY STAR score, Site EUI, Source EUI, and total GHG emissions — all of which appear in the city's public disclosure.

How to File

1. Create or log in to your ENERGY STAR Portfolio Manager account at portfoliomanager.energystar.gov
2. Add the property with the correct address, GFA, and occupancy details
3. Enter full-year energy and water data (12 consecutive months)
4. Share the property with the NYC Department of Finance directly in ESPM (this is the submission step)

The share-to-NYC step is the official filing. Simply entering data in ESPM without sharing is not sufficient — the city must have access to your property's data in Portfolio Manager by May 1.

Penalties for Non-Filing

Buildings that fail to file by the May 1 deadline receive a violation from the NYC Department of Finance. Fines are assessed as:

• $500 per violation per quarter for continued non-compliance

Violations accumulate until the filing is completed. Buildings in default also lose access to the city's public benchmarking disclosure record, which can affect property valuations and financing.

Common Filing Mistakes to Avoid

• Default ESPM values: ESPM pre-fills certain occupancy fields with default values. Filing with defaults instead of actual data is a common error that affects ENERGY STAR score accuracy and LL97 compliance calculations.
• Missing utility data: Gaps in monthly energy data (even one month) can prevent ESPM from generating an ENERGY STAR score and produce an incomplete filing.
• Incorrect GFA: GFA errors ripple through both EUI calculations and LL97 emissions cap calculations. Use actual measured GFA, not assessor estimates.
• Forgetting the share-to-NYC step: Data must be shared with the NYC Department of Finance inside ESPM. Entering data without this step does not constitute a valid filing.
• Year-over-year outliers: Large unexplained changes in energy use (e.g., 40% jump) can trigger data quality reviews. Review year-over-year trends before filing.

Pre-Filing Review with EnergiDash

EnergiDash's Benchmarking Checker tool lets you review your entire portfolio in bulk before the May 1 deadline. It flags missing data, default values, year-over-year anomalies, and buildings where ESPM cannot generate an ENERGY STAR score — so you can resolve issues before they become part of the official compliance record.