Everything you need to know about BEPS

What is BEPS?

BEPS is Washington DC’s Building Energy Performance Standards- the city’s goal to reduce greenhouse gas emissions by 50% by 2032, with the end goal of becoming completely carbon neutral by 2045. It differs from NYC and Boston’s ordinances in that it penalizes building owners based on the gap between current performance and the target. 

Under the recent August 11, 2026 update (Guidebook v1.2), the DOEE introduced new options and accomodations to support building owners with steep barriers to compliance.

Who Qualifies?

Large Buildings: Starting 2026, buildings 50,000 square feet or larger will be formally evaluated.

Mid-Size Buildings: Buildings 25,000-49,000 square feet are not subject to any targets yet, but owners must continue benchmarking and submit energy data by May 1 2026. 

Small Buildings: Buildings 10,000-24,999 square feet must start benchmarking. Targets will apply in 2033.

Event Large Buildings (50,000+ sq ft) Mid-size Buildings (25,000–49,999 sq ft) Small Buildings (10,000–24,999 sq ft)
2026
  • Final year of Compliance Cycle 1 All operational and retrofit improvements must impact this calendar year's data by Dec 31
  • Owners facing barriers may apply for flexible penalty relief under Guidebook v1.2
  • Continue annual benchmarking period
  • Submit annual energy and water usage data via ENERGY STAR Portfolio Manager by May 1
  • Submit first mandatory benchmarking report by May 1 (covering CY 2025 data)
  • Begin continuous annual recording and reporting via ENERGY STAR Portfolio Manager
April 1, 2027
  • Completed Actions Report due
  • Submit official documentation to DOEE detailing all compliance measures and retrofits taken
  • No action needed
  • No action needed
May 1, 2027 (evaluation & standard setting)
  • Submit third-party verified benchmarking data from 2026
  • DOEE evaluates Cycle 1 performance
  • Buildings falling short pay a fine or seek Guidebook v1.2 penalty relief/waivers
  • Continue annual benchmarking
  • DOEE establishes Cycle 2 baseline standards for mid-size property types
  • Continue annual benchmarking and reporting
  • No compliance requirements yet
2028–2032
  • Compliance Cycle 2 active
  • Implement further energy efficiency retrofits and strategies to meet updated standards
  • Compliance Cycle 1 begins for mid-size buildings (Jan 1, 2028)
  • Implement retrofits and strategies to meet assigned BEPS targets by Dec 31, 2032
  • Continue annual benchmarking and reporting
  • No performance targets required yet
May 1, 2033 (evaluation)
  • Submit third-party verified benchmarking data from 2032 for Cycle 2 compliance evaluation
  • Submit third-party verified benchmarking data from 2032
  • DOEE evaluates building performance against property type standard
  • Non-compliant buildings pay proportional fine
  • Final benchmarking year prior to Cycle 3
  • DOEE establishes baseline standards for small building property types
2034–2038
  • Compliance Cycle 3 active
  • Compliance Cycle 2 active
  • Compliance Cycle 1 begins for small buildings (Jan 1, 2034)
  • Implement energy efficiency retrofits and strategies to meet BEPS targets by Dec 31, 2038
May 1, 2039 (evaluation)
  • Submit verified benchmarking data from 2038 for Cycle 3 evaluation
  • Submit verified benchmarking data from 2038 for Cycle 2 evaluation
  • Submit third-party verified benchmarking data from 2038
  • DOEE evaluates building performance against property type standard
  • Non-compliant buildings pay proportional fine

Consequences of Non-Compliance

D.C. has a unique approach to penalizing non-compliant buildings. While the maximum fine is $10/square foot, capped at $7.5M per property, they have a proportional deduction system. For example, if the building’s goal was to reduce their energy expenditure by 20% to get below the median, but only achieved a 15% reduction in energy usage, the building would only pay proportional to the five percentage points (25% of the fine).

A “Good Faith Effort” framework will be released in late 2026, outlining a mechanism for potential compliance payment reductions due to outlying circumstances. 

Resources:

BEPS v1.2 Guidebook

BEPS help desk