If your NYC building still hadn’t filed its Local Law 84 benchmarking report by November 1, 2026, it can now carry up to $1,500 in violations for this filing year: $500 for May 1, $500 for August 1 and $500 for November 1. File a compliant report before February 1, 2027 to avoid the fourth $500 penalty. The penalties stop once a compliant report is in.
What is the November 1 checkpoint?
Local Law 84 benchmarking reports are due May 1 each year and cover the previous calendar year’s energy and water use. The 2026 filing covers January to December 2025.
If a covered building misses May 1, the Department of Buildings (DOB) doesn’t wait a full year to penalize it. It checks again every quarter:
| Checkpoint | Penalty if still not filed | Running total |
|---|---|---|
| May 1, 2026 | $500 | $500 |
| August 1, 2026 | $500 | $1,000 |
| November 1, 2026 | $500 | $1,500 |
| February 1, 2027 | $500 | $2,000 (annual maximum) |
November 1 is the third of those four checkpoints. If your report wasn’t in by then, expect a third Notice of Violation.
What you owe right now
The benchmarking violation is $500 per missed checkpoint, capped at $2,000 per filing year. The fine isn’t the only cost, though:
- Your energy grade. A building that doesn’t benchmark gets an F on its Building Energy Efficiency Rating label. The label has to be posted at every public entrance, so tenants, buyers and lenders see it.
- Your Local Law 97 report. The LL97 emissions report uses the same 2025 energy data. Without a clean benchmarking file you are building that report on guesswork.
- Next year’s filing. Unpaid penalties and unresolved violations make every later interaction with DOB harder, so clear them before the May 1, 2027 cycle starts.
How to stop the penalties: 5 steps
1. Confirm the building is really covered
Check your BBL (borough-block-lot) on the City’s current Covered Buildings List. If you think the building is listed by mistake, for example because of a wrong square footage, ask the Department of Finance to correct it. Don’t just leave the report unfiled.
2. Pull 12 months of whole-building data
You need January–December 2025 energy use for the whole building: electricity, natural gas, district steam and fuel oil, including separately metered tenant spaces. Add water use if the Covered Buildings List says your building must report it. The fastest route is to request aggregated whole-building data from Con Edison or National Grid. It uploads automatically into ENERGY STAR Portfolio Manager, so you don’t have to chase individual tenants.
3. Set up the property correctly in Portfolio Manager
Check the gross floor area, the property use types (office, multifamily, retail and so on) and the BBL/BIN identifiers. These must match Department of Finance records. These three fields cause most rejected filings and most unfairly low grades.
4. Submit and keep the confirmation
Generate the City’s reporting template for the compliance year and submit the report to NYC from Portfolio Manager. Save the confirmation email with its date-stamped copy of the data. That email is your proof if a violation arrives anyway.
5. Pay or challenge each violation
Violations issued since December 2024 can be looked up in the DOB NOW Public Portal by address, BBL or BIN. Since December 15, 2025, LL84 penalties are paid in DOB NOW: Safety. You can’t pay in person or by mail.
If a violation is wrong, for example because you filed on time and have the confirmation, you can challenge it. Submit the challenge within 30 days of the violation’s postmark, with supporting documents.
Can I get an extension?
No. LL84 has no standing extension process. DOB has granted one-off extensions in past years, but there is none for the 2026 filing. The only way to stop the clock is to file.
What if we’re a new owner?
A building that changed hands may have inherited unfiled years. If you bought it in good faith from an unrelated seller, the violation challenge rules include a route for that situation. It requires a copy of the deed and a notarized affidavit. Talk to a benchmarking specialist before you pay penalties that may not be yours.
Frequently asked questions
Do penalties keep piling up after February 1?
No, not for this filing year. The penalty is capped at $2,000 per year. But the May 1, 2027 report for 2026 data starts its own penalty clock.
If I file now, will my energy grade change from F?
Filing stops the penalties. Grades are issued once a year, on October 1, from the latest benchmarking data. A late 2026 filing makes sure next year’s label shows a real score rather than an F.
Who receives the violation, the owner or the property manager?
The owner. The law puts the duty on the owner of the covered building, even when a manager or consultant does the work.
Can I file the report myself?
Yes. Portfolio Manager is free, and the NYC Sustainability Help Center offers free guidance at (212) 566-5584. Most mistakes come from incomplete tenant data and wrong property types, which is where a specialist saves time.
Get it filed before February 1
Send us your building address or BBL. We’ll confirm coverage, check for open benchmarking violations and tell you exactly what’s needed to file, free, within one business day.
Click to get a free benchmarking check.
Phone: +1(212) 889-6566