| May 1, annually (ongoing) |
- Submit annual energy and water use data via ENERGY STAR Portfolio Manager
- Third-party data verification required for baseline years (2018–2019) and the first year of each compliance period
|
- Submit annual energy and water use data via ENERGY STAR Portfolio Manager
- Third-party data verification required for baseline years (2018–2019) and the first year of each compliance period
|
| 2026 — Compliance Period 1 begins |
- Emissions reduction requirements begin
- Annual GHG emissions must be reduced by at least 20% from the 2018–2019 baseline for each year through 2029
- Penalties apply: $234/metric ton of CO₂ over the limit + $300/day for reporting failures
|
- No active reduction target yet
- Buildings must maintain emissions at or below baseline (no increases allowed)
- Annual benchmarking and reporting continue
- Penalties apply for reporting failures ($300/day)
|
| 2026–2029 |
- Annual reporting due May 1
- Achieve ≥20% GHG reduction from baseline each year
- Verified Carbon Credits (VCCs) not yet available as a compliance tool
|
- Annual reporting due May 1
- Hold emissions at or below baseline
- No active reduction penalties yet during this period beyond reporting obligations
|
| 2030 — Compliance Period 2 begins |
- Targets tighten significantly
- Annual GHG emissions must be reduced by at least 60% from baseline
- VCCs become available as a limited compliance option (city must publish criteria by end of 2028)
- Penalties continue at $234/ton over limit
|
- Active emissions reduction requirements begin
- Annual GHG emissions must be reduced by at least 40% from the 2018–2019 baseline
- Penalties now apply for exceeding emissions targets ($234/ton over limit)
- Third-party verification required for first year of this period
|
| 2030–2034 |
- Annual reporting due May 1
- Achieve ≥60% GHG reduction from baseline each year
- Limited use of VCCs and Alternative Compliance Credits allowed
|
- Annual reporting due May 1
- Achieve ≥40% GHG reduction from baseline each year
- Penalties apply if building exceeds carbon cap
|
| 2035 — Net zero required (Cohort 1) |
- Buildings must achieve net-zero greenhouse gas emissions
|
- Compliance Period 3 begins
- Annual GHG emissions must be reduced by at least 60% from baseline
- Penalties apply if building exceeds carbon cap
|
| 2035–2039 |
- Maintain net-zero emissions annually
- Ongoing annual reporting and verification required
|
- Annual reporting due May 1
- Achieve ≥60% GHG reduction from baseline each year
- Penalties apply if building exceeds carbon cap
|
| 2040 — Compliance Period 4 (Cohort 2) |
- Maintain net-zero emissions annually
- Ongoing annual reporting and verification required
|
- Compliance Period 4 begins
- Annual GHG emissions must be reduced by at least 80% from baseline
- Penalties apply if building exceeds carbon cap
|
| 2040–2044 |
- Maintain net-zero emissions annually
- Ongoing reporting required
|
- Annual reporting due May 1
- Achieve ≥80% GHG reduction from baseline each year
- Penalties apply if building exceeds carbon cap
|
| 2045 — Compliance Period 5 (Cohort 2) |
- Maintain net-zero emissions annually
- Ongoing reporting required
|
- Compliance Period 5 begins
- Buildings must be on a clear trajectory toward net zero
- Emissions reduction targets continue to tighten
- Penalties apply if building exceeds carbon cap
|
| 2045–2049 |
- Maintain net-zero emissions annually
- Ongoing reporting required
|
- Annual reporting due May 1
- Continued GHG reduction requirements
- Penalties apply if building exceeds carbon cap
|
| 2050 — Net zero required (Cohort 2) |
- Buildings must maintain net-zero greenhouse gas emissions
|
- Buildings must achieve net-zero greenhouse gas emissions
- No emissions deferrals may allow emissions to exceed zero after 2050
|
