7 Emissions Reporting Mandates You Should Know About

As the urgency to combat climate change intensifies, cities and states across the U.S. are implementing stricter regulations on greenhouse gas (GHG) emissions, particularly for commercial and large residential buildings.  

These emission reporting mandates not only help achieve ambitious climate goals, theybut they also hold organizations accountable for their environmental impact. Whether you're a building owner, facility manager, or sustainability officer, staying on top of these evolving regulations is crucial for compliance and for contributing to a greener future.  

In this blog, we'll explore seven key emissions reporting mandates that every building owner should be aware of, outlining the requirements, deadlines, penalties, and incentives associated with each. 

California 

The California Energy Commission's (CEC) 2022 Building Energy Efficiency Standards (Energy Code) update aims to transition new buildings away from fossil fuel use by setting minimum efficiency standards for walls, windows, and heating/cooling systems.  

A key change is the shift to electric heat pumps for space and water heating, which can reduce greenhouse gas emissions by up to 75% compared to the most efficient gas furnaces. The code, which applies to new constructions and is updated every three years, encourages energy-efficient solutions and discourages the use of gas for heating and hot water.  

Buildings that use high-efficiency electric systems can avoid additional expensive updates, while those using gas must compensate through other efficiency measures, such as improved insulation and windows. This flexible approach provides financial incentives for reducing carbon emissions and energy costs. 

Colorado 

Colorado’s House Bill 21-1286 requires owners of large buildings (over 50,000 square feet) to annually report energy-usage data to the Colorado Energy Office. The goal is to reduce greenhouse gas emissions by 7% by 2026 and 20% by 2030 compared to 2021 levels.  

When these buildings are leased or sold, owners must provide an electronic copy of the previous year's benchmarking data. The mandate applies to buildings with a gross floor area of at least 50,000 square feet occupied by a single tenant or group of tenants, excluding storage facilities, parking garages, airplane hangars, and buildings with more than half of their space used for manufacturing, industrial, or agricultural purposes. 

Massachusetts 

To preserve clean air for residents, workers, and visitors, Massachusetts requires certain facilities to report and limit emissions to control air pollution at its origin. The state’s Greenhouse Gas Reporting applies to facilities emitting more than 5,000 short tons of CO2e per year, providing transparency and pushing facilities toward greener operations.  

Boston also has its own reporting requirements vis the Building Emissions Reduction and Disclosure Ordinance (BERDO). BERDO requires buildings over 20,000 square feet (or 15+ residential units) to report emissions annually.  

Beginning in 2025, carbon intensity limits will apply to buildings over 35,000 square feet, incentivizing energy efficiency and helping to meet the city’s climate goals. In 2030, these limits will expand to buildings between 20,000 – 35,000 square feet. Both building categories are already required to report annual emissions.  

New York 

New York City’s Local Law 97 is aimed to reduce greenhouse gas emissions from large buildings by 40% by 2030 and achieve an 80% reduction citywide by 2050. The law applies to all commercial buildings and multifamily units larger than 25,000 square feet, and to properties with multiple buildings exceeding 50,000 square feet combined.  

As of 2024, building owners must report annual greenhouse gas emissions, with penalties for non-compliance, failure to report, or providing false information. These penalties include fines based on excess CO2 emissions and square footage. While no direct incentives are offered through the law, building owners are encouraged to explore other available city, state, and federal incentive programs. 

This initiative is part of New York City’s broader efforts to foster sustainability and reduce its carbon footprint, encouraging buildings to improve their energy efficiency and reduce emissions over time. 

Pennsylvania 

In Pennsylvania, the city of Philadelphia’s Building Energy Performance program aims to reduce carbon pollution by nearly 200,000 metric tons, equivalent to removing 40,000 cars from the road. Building owners must comply with benchmarking requirements, reporting key attributes like the building’s address, gross floor area, operating hours, and specific energy usage details.  

These reports must be filed regardless of tenant cooperation, with owners only responsible for available information. The mandate applies to buildings with at least 50,000 square feet of floor space, including those in the Commercial Property Assessed Clean Energy (C-PACE) program. The initiative is designed to promote energy efficiency and support the city’s sustainability goals. 

Washington State 

Washington State’s Clean Building Performance Standards program, introduced in 2019 and expanded in 2022, aims to reduce fossil fuel consumption in existing buildings by encouraging energy efficiency improvements.  

The program requires building owners to benchmark their buildings' energy use and integrate them into the ENERGY STAR Portfolio Manager (ESPM). Compliance is mandatory for Tier 1 buildings (over 50,000 square feet) and Tier 2 buildings (20,000–50,000 square feet), including multifamily buildings over 50,000 square feet. The program incentivizes early energy upgrades, with financial rewards for those who improve energy efficiency earlier than required. 

Penalties for non-compliance can reach up to $5,000 plus an annual fee based on the building’s size. Tier 1 buildings can apply for exemptions, and the program includes significant incentives, such as a $0.85 per square foot base payment for early adopters.  

The regulations for Tier 1 buildings will be phased in starting in 2026, with Tier 2 reporting beginning in 2027. By promoting energy efficiency, the program helps Washington meet its climate goals while providing financial benefits to building owners who comply. 

Washington, D.C. 

The Building Energy Performance Standard (BEPS) program in Washington, D.C. is part of the city's efforts to reduce greenhouse gas emissions by 50% by 2032 and achieve carbon neutrality by 2050.  

The program requires buildings of certain sizes to comply with energy efficiency standards, using various pathways such as the performance pathway (requiring a 20% reduction in energy use intensity) and the prescriptive pathway (focused on implementing energy-saving measures). As of 2023, privately owned buildings of at least 25,000 square feet must comply, with those over 10,000 square feet expected to report by 2026. 

Non-compliance can result in penalties, including fines, civil actions, and fees. Exemptions are available for buildings undergoing major renovations or facing financial distress. This initiative encourages energy efficiency upgrades and aims to significantly reduce the city's carbon footprint while supporting long-term climate goals. 

Conclusion 

As emissions reporting mandates continue to evolve across the U.S., building owners and facility managers must stay ahead of these regulations to ensure compliance and contribute to broader climate goals. While each of the seven mandates discussed plays a crucial role in reducing greenhouse gas emissions, promoting energy efficiency, and encouraging sustainable practices, they are only a small number of the requirements being enforced across the country.  

Despite recent rumblings around the future of climate-related disclosures, there are still benefits to understanding the regulations in your city or state, and taking proactive steps toward meeting them.  Proving your sustainability efforts can not only help you avoid penalties, it can also unlock potential financial incentives, improve operational efficiency, and increase trust among your customers and current or future investors.  

Environmental sustainability is often seen as a complex, long-term challenge. But starting your journey to reducing emissions and achieving Net Zero doesn’t have to be hard. You can start by learning more about ways to both calculate your carbon footprint and 10 ways you can reduce your environmental impact. 

If you’re ready for a bit more, download our Simplifying Sustainability guide for actionable tips on how you can take the first steps on a journey to Net Zero.