Building Performance Standards Beyond NYC: Boston, Washington, Colorado
Who is covered and what is due under Boston’s BERDO, Washington’s Clean Buildings standard, Building Performance Colorado and Energize Denver.
By Seayora Editorial Team · Published · Facts checked · 4 min read
Short answer: New York City’s Local Law 97 is not the only building emissions law. Boston’s BERDO sets emissions limits for residential buildings with 15 or more units and non-residential buildings of 20,000 square feet or more, starting in 2025 or 2030 by size, with a $234-per-ton payment option. Washington State’s Clean Buildings standard requires reports from 2026 to 2028 for buildings over 50,000 square feet and by July 1, 2027 for multifamily over 20,000, and Colorado and Denver set targets for buildings of 50,000 and 25,000 square feet.
Key takeaways
- Boston: emissions limits begin in 2025 for 35,000+ sq ft or 35+ units, and in 2030 for 20,000–34,999 sq ft or 15–34 units; net zero by 2050.
- Boston: an alternative compliance payment of $234 per metric ton of CO2e above the limit.
- Washington State: Tier 1 reports due June 1, 2026, 2027 or 2028 by size; Tier 2, including multifamily over 20,000 sq ft, due July 1, 2027.
- Colorado: most commercial buildings 50,000 sq ft and larger benchmark yearly, with reports and fees due November 1.
- Denver: Energize Denver covers buildings from 5,000 sq ft; for 25,000 sq ft and larger, deadlines were extended to 2028 and 2032.
Which cities and states have building performance standards?
Benchmarking laws make owners report a building’s energy use; building performance standards go further and require it to meet a limit. New York City’s Local Law 97 is the best known (see our Local Law 97 guide), but Boston, Washington State, Colorado and Denver have their own, each with different size thresholds, metrics and deadlines. Several others exist or are being adopted; this guide covers four, read from each program’s official pages.
| Program | Who is covered | Key dates | Source |
|---|---|---|---|
| Boston BERDO | Residential with 15+ units; non-residential 20,000+ sq ft; parcels summing to either | Emissions limits from 2025 (35,000+ sq ft or 35+ units) or 2030 (smaller); net zero by 2050 | City of Boston |
| Washington State Clean Buildings | Tier 1: non-residential over 50,000 sq ft; Tier 2: 20,001–50,000 sq ft and multifamily over 20,000 sq ft | Tier 1 reports June 1, 2026, 2027 or 2028 by size; Tier 2 by July 1, 2027 | Washington State Department of Commerce |
| Building Performance Colorado | Most commercial buildings 50,000 sq ft and larger | Benchmarking report and fee due November 1 each year | Colorado Energy Office |
| Energize Denver | Commercial and multifamily 5,000 sq ft and larger | For 25,000+ sq ft, interim and final targets extended to 2028 and 2032 | City and County of Denver |
What does Boston’s BERDO require?
The Building Emissions Reduction and Disclosure Ordinance covers residential buildings with 15 or more units, non-residential buildings of 20,000 square feet or more, and tax parcels whose buildings together reach either size. Owners report annual energy and water use, and buildings must meet annual emissions standards starting in 2025 (35,000 square feet or more, or 35 or more units) or 2030 (20,000 to 34,999 square feet, or 15 to 34 units), declining to net zero by 2050 (City of Boston). A building over its limit can comply by making alternative compliance payments of “$234 for every metric ton of CO2e a building is above its emissions limit” (BERDO emissions compliance guide).
What does Washington’s Clean Buildings standard require?
A Tier 1 building is one whose non-residential, hotel, motel and dormitory floor area exceeds 50,000 square feet, excluding parking. Compliance reports are due June 1, 2026 for buildings over 220,000 square feet, June 1, 2027 for those over 90,000, and June 1, 2028 for those over 50,000 (Tier 1 compliance). Tier 2 covers non-residential buildings over 20,000 and up to 50,000 square feet and multifamily residential buildings over 20,000 square feet; their reports are due July 1, 2027, and they are “not required to meet a performance target at this time” (Tier 2 compliance).
What do Colorado and Denver require?
Building Performance Colorado combines benchmarking and building performance standards for “most commercial buildings 50,000 square feet and larger.” The benchmarking period opens July 1 and the report and fee are due November 1 each year, with penalties for late reports, and the program supports the state’s goals of cutting commercial building emissions 7% by 2026 and 20% by 2030 from 2021 levels (Colorado Energy Office).
Energize Denver applies to commercial and multifamily buildings of 5,000 square feet and larger, with separate requirements below and above 25,000 square feet (Energize Denver). In February 2026 the state and city announced that Denver buildings complying with Energize Denver will be deemed in compliance with part of the state program, that interim and final targets for buildings of 25,000 square feet and larger were extended to 2028 and 2032, and that the state will not begin enforcing performance targets until after 2030, while state benchmarking fees still apply (City and County of Denver).
What should an owner do first?
- Confirm whether each building is covered, using the program’s own covered-buildings list where one exists.
- Benchmark in ENERGY STAR Portfolio Manager with a full year of whole-building data; every program here relies on it.
- Calendar the reporting date and the first target year for each building.
- Plan capital work against equipment replacement cycles, since the targets tighten over time.
Frequently asked questions
Does Boston’s BERDO apply to apartment buildings?
Yes, to residential buildings with 15 or more units. Those with 35 or more units face emissions limits from 2025; those with 15 to 34 units from 2030.
Do multifamily buildings in Washington State have to comply with Clean Buildings?
Multifamily residential buildings over 20,000 square feet are Tier 2 buildings, with reports due by July 1, 2027. Tier 2 buildings do not have to meet a performance target at this time.
When are Colorado benchmarking reports due?
November 1 each year for covered buildings of 50,000 square feet and larger, with the reporting period opening July 1.
Sources
- Building Emissions Reduction and Disclosure (BERDO), City of Boston
- How to comply with your BERDO emissions standard, City of Boston
- Clean Buildings Performance Standard: Tier 1 compliance, Washington State Department of Commerce
- Clean Buildings Performance Standard: Tier 2 compliance, Washington State Department of Commerce
- Building Performance Colorado, Colorado Energy Office
- Energize Denver Building Performance Policy, City and County of Denver
- Rules and Technical Guidance, buildings 25,000 sq ft or larger, City and County of Denver
How Seayora helps
ENERGY STAR Portfolio Manager: Connect your Portfolio Manager account, share buildings, and keep each building’s benchmarking data current.
This article is general information, not legal or engineering advice. Local Law 97 is amended by local law and by Department of Buildings rule, so confirm a building’s obligations with the Department of Buildings or a registered design professional before you file.
How we write and check these guides: editorial standards.
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