This Local Law 97 compliance guide is for the owner or manager of a New York City building over 25,000 square feet who has filed the first annual emissions report and now has to plan for the 2030 limits. Local Law 97 of 2019 sets a carbon emissions cap for each covered building, expressed in metric tons of CO2 equivalent per square foot per year, that tightens in steps: one set of limits for 2024 to 2029, a much lower set for 2030 to 2034, and further reductions to 2050. A building that emits more than its limit pays a penalty of $268 per metric ton over, every year, and the report showing where the building stands is due to the Department of Buildings by May 1 each year, certified by a registered design professional.

Most buildings are inside their 2024 limit. Most are not inside their 2030 limit, and the gap is large enough that the work to close it takes years to plan, finance and build. This guide covers who is covered, the limits by building type, a worked penalty calculation for a 200,000 square foot building, what the annual report requires, the good-faith and mediated extension routes, the reduction measures ranked by what they cost per ton, and how to keep the emissions data straight in the utility system so that the May filing is a report rather than a project.

Last reviewed: September 2026, against the NYC Department of Buildings' Local Law 97 rules (1 RCNY 103-14) and the 2026 covered buildings list.

Local Law 97 at a glance

Who is covered

Local Law 97 applies to buildings on the covered buildings list that the Department of Buildings publishes each year, drawn from the same population as the benchmarking law (Local Law 84). A building is covered if it exceeds 25,000 gross square feet; if two or more buildings on the same tax lot together exceed 50,000 square feet; or if two or more buildings held in the condominium form and governed by the same board together exceed 50,000 square feet.

Exemptions and alternative pathways cover industrial facilities used for power generation, certain city-owned and religious properties, and buildings with a high share of rent-regulated units. That last group is the important one for residential owners: buildings where more than 35% of units are rent-regulated, HDFC cooperatives, and certain affordable housing follow Article 321 rather than the emissions limits, which requires a set of prescriptive energy conservation measures (or demonstrating emissions below the 2030 limit) instead of paying on tonnes over, until the limits apply to them from 2035.

The list is published annually and a building's status can change with a lot merger, a condominium conversion or a change in rent-regulated unit count, so the first step in each compliance year is to confirm the building is on the list and under which article.

The limits by building type

The limits are expressed as tCO2e per gross square foot per year and are set by the building's use, weighted across uses in a mixed-use building. The 2024 to 2029 limits were set in the law by building-code occupancy group; the Department of Buildings' rule (1 RCNY 103-14) maps those to Energy Star Portfolio Manager property types and sets the 2030 to 2034 limits by property type, which is why the two columns below use slightly different labels. The rule is the source for the exact figure for any given property type.

Two features of the LL97 2030 limits drive the planning. The 2030 step is not a modest tightening; for most property types it removes half to four-fifths of the allowance. And the reductions are uneven: retail and warehouse space lose more allowance than multifamily, which matters for a mixed-use building whose ground-floor retail was helping the blended limit in 2024.

Emissions are calculated from metered energy using coefficients the law and the rule set for each period. For 2024 to 2029, electricity from the grid is counted at 0.000288962 tCO2e per kWh, natural gas at 0.00005311 tCO2e per kBtu, district steam at 0.00004493 tCO2e per kBtu, and fuel oils at their own factors (No. 2 oil 0.00007421 per kBtu). For 2030 to 2034 the rule lowers the electricity coefficient to 0.000145 tCO2e per kWh to reflect a cleaner grid, which helps buildings that have electrified and does nothing for buildings still burning gas.

Worked example: emissions vs limit vs penalty

Take a 200,000 gross square foot multifamily building (R-2) with 1,800,000 kWh of electricity and 15,000 MMBtu (15,000,000 kBtu) of natural gas a year, a common profile for a post-war rental with gas heating and hot water.

The building is compliant today by a margin of about 2.5%, and in 2030, with no change to the building at all and a cleaner grid doing some of the work, it is 388 tonnes over and owes roughly $104,000 a year, every year, until it either reduces emissions or the limits tighten again in 2035. The gas line is the problem: it does not benefit from the grid coefficient and it is three-quarters of the 2030 total.

Two further LL97 penalties sit alongside the emissions penalty. Failure to file the annual report carries a penalty of $0.50 per gross square foot per month, up to twelve months, which on this building is $100,000 a month. A false or misleading statement in the report carries a penalty of up to $500,000.

Reporting: what, when, who signs

The annual report covers the previous calendar year's energy use and is due by May 1. For the first filing, covering 2024, the Department of Buildings granted an extension into late August 2025; do not assume one will be granted again. Each subsequent year the LL97 reporting deadline May 1 stands unless DOB says otherwise, and a request for an individual extension has to be made before the deadline, not after.

The report is filed through DOB's online BEAM portal (linked from the DOB Local Law 97 page) and must contain: the building's identifiers and gross floor area by property type; twelve months of metered energy consumption for every fuel and utility account serving the building, including tenant-metered accounts (which the utility can supply in aggregate on request); the emissions calculation using the period's coefficients; any deductions claimed for renewable energy credits (allowed against grid electricity where the generation is deliverable to the city's grid zone) or carbon offsets (limited to a capped share of the building's limit in the first period); and the certification.

The certification is what makes the filing different from benchmarking. A registered design professional, a licensed professional engineer or registered architect, must certify the report as accurate. That is a paid engagement with its own timeline, and it means the building's energy data has to be assembled, reconciled to utility bills and reviewed before the professional will sign, which in practice means the work starts in January, not April.

Keep the underlying records for the period the rule requires (several years) because DOB audits filings, and the $500,000 false statement penalty attaches to the owner, not the certifier.

Good-faith and mediated extensions

The Department of Buildings' rules provide two routes for buildings that cannot meet their limit on time, and both require applying, not waiting.

Under the good-faith efforts provisions, an owner whose building exceeds its 2024 to 2029 limit can have the penalty reduced or waived if the owner demonstrates good-faith efforts to comply. The criteria include: having filed benchmarking and the LL97 report on time; being in compliance with related energy laws (the lighting upgrade and submetering requirements of Local Law 88, the energy audit and retro-commissioning requirements of Local Law 87); having submitted a decarbonization plan that shows how the building will meet its 2030 limit, with the work scheduled; and meeting the interim milestones in that plan in the years that follow. The plan route is the one most owners of the example building above should be on now, because it converts a penalty into a schedule.

A mediated extension is available where the owner shows that compliance is not feasible for financial or technical reasons in the period, and defers the obligation for a defined period on terms agreed with DOB. It is narrower, requires documentation of the constraint, and does not remove the eventual obligation.

Neither route is automatic, and both depend on the building having a clean filing history. An owner who missed a benchmarking submission in 2023 has a weaker case for good faith in 2027.

Reduction pathways ranked by cost per ton

The way to plan the 2030 gap is to price each measure in dollars per tonne of annual CO2e removed, and to do the cheap ones first. The ranking below is typical for a gas-heated NYC multifamily or office building; the numbers are order-of-magnitude and a building-specific energy audit replaces them.

For the example building, the operations, envelope and hot water measures might remove 150 to 250 tonnes and cost a few hundred thousand dollars against a $104,000 annual penalty; partial electrification of heating removes the rest. A conversion that cuts gas by 60% and adds 2.2 million kWh of electricity takes the building to about 899 tonnes in 2030, still 229 over, which is why the plan needs the full sequence and why it takes years.

Financing matters as much as engineering. NYC's commercial PACE programme (Local Law 96), NYSERDA incentives and Con Edison's clean heat programmes exist to fund exactly this work, and the NYC Accelerator, the city's free advisory service, helps owners assemble the plan. The decarbonization plan submitted under the good-faith rules should reference the funding it relies on.

Tracking emissions data in the utility system

The May filing is only as good as the twelve months of consumption data behind it, and most buildings assemble that data from PDFs of utility bills, a benchmarking consultant's spreadsheet and a tenant-metering vendor's export, once a year, in April. That is why the certification takes weeks and why the number is never quite the same as last year's.

The alternative is to hold every utility account, meter and fuel delivery for the building in the property system as it is billed, with the consumption (kWh, therms, kBtu, gallons) captured alongside the cost, so that the twelve months of data the filing needs already exist, reconciled to the bills, by the time the certifier asks for them.

In RIOO on NetSuite, the utility asset and meter management module holds the building's utility accounts and meters and records consumption from utility bills and meter reads, with the fuel type and units on every reading. Tenant-metered consumption comes through the same resident utility billing records that produce the tenant charges, so the whole-building total is in one place. That consumption record, by fuel and by month, is what the emissions calculation and the annual filing are built from; how it feeds ESG reporting and the energy audit is covered in those guides.

Frequently asked questions

Q1. Which buildings are covered by Local Law 97?
Buildings over 25,000 gross square feet, groups of buildings on one tax lot totalling over 50,000 square feet, and condominium buildings under one board totalling over 50,000 square feet, as listed on the Department of Buildings' annual covered buildings list. Buildings with more than 35% rent-regulated units, HDFC co-ops and certain affordable housing follow the Article 321 prescriptive pathway instead of the emissions limits until 2035.

Q2. What are the LL97 emissions limits for multifamily buildings?
0.00675 tCO2e per square foot per year for 2024 to 2029, and 0.00334664 tCO2e per square foot for 2030 to 2034, a 50% reduction. A 200,000 square foot multifamily building's limit falls from 1,350 tonnes to about 669 tonnes in 2030.

Q3. What is the penalty for exceeding the Local Law 97 limit?
$268 per metric ton of CO2e over the limit, assessed annually. Failure to file the annual report costs $0.50 per gross square foot per month for up to twelve months, and a false or misleading statement can cost up to $500,000. Penalties can be reduced or waived under the good-faith efforts rules for owners with a decarbonization plan and a clean filing history.

Q4. When is the Local Law 97 report due?
By May 1 each year, covering the previous calendar year, filed through the Department of Buildings' portal and certified by a registered design professional (a licensed professional engineer or registered architect). DOB granted an extension for the first filing in 2025; later years should be planned to the May 1 date.

Q5. How are LL97 emissions calculated?
Metered consumption of each fuel and utility for the calendar year, including tenant-metered accounts, multiplied by the period's coefficient (for 2024 to 2029: 0.000288962 tCO2e per kWh of grid electricity, 0.00005311 per kBtu of natural gas, 0.00004493 per kBtu of steam), less any eligible renewable energy credit or capped carbon offset deductions, compared with the building's limit (gross floor area by property type times the limit for each type).

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