Energy Audit Compliance by City
What is energy audit compliance?
Energy audit compliance means meeting a city or state law that requires buildings to complete an energy audit, retro-commissioning (RCx) or a building tune-up on a set schedule. These rules usually sit alongside an energy benchmarking ordinance: benchmarking shows how much energy a building uses, while audits and tune-ups find out why and what to fix.
The requirements below cover the main US programs in 2026, with links to our full guide for each city. Energy Fave’s Professional Engineers and Certified Energy Managers perform ASHRAE Level 2 and Level 3 energy audits for building owners nationwide.
Which cities require energy audits?
These cities require a periodic energy audit, energy assessment, retro-commissioning or tune-up, based on each program’s 2026 rules:
| City | What is required | How often |
|---|---|---|
| New York City (LL87)Over 50,000 sq ft | ASHRAE Level 2 energy audit and retro-commissioning, filed as an Energy Efficiency Report | Every 10 years |
| Los Angeles (EBEWE)20,000+ sq ft | Energy and water audit plus retro-commissioning (A/RCx), or an exemption for high performers | Every 5 years |
| San FranciscoNon-residential | Energy audit | Every 5 years |
| Berkeley (BESO)15,000+ sq ft | Energy assessment | Every 5 years for 25,000+ sq ft; before sale for 15,000–24,999 sq ft |
| BoulderCovered buildings | ASHRAE 211 energy assessment and retro-commissioning, plus a one-time lighting upgrade | Every 10 years |
| AtlantaCovered buildings | Energy audit, scheduled by the last digit of the building ID | Every 10 years |
| Austin (ECAD)Multifamily and homes | Energy audit for multifamily properties and for homes being sold | When a multifamily property turns 10; before a home sale |
| Orlando50,000+ sq ft | Energy audit or retro-commissioning for ENERGY STAR scores below 50 | Every 5 years until the score reaches 50 |
| Philadelphia (BEPP)Non-residential 50,000+ sq ft | Building tune-up, unless the building shows high performance | Every 5 years |
| MadisonCommercial 50,000+ sq ft | Building tune-up (first tune-ups began in 2026) | Every 4 years |
| Salt Lake CityLow ENERGY STAR scores | Tune-up evaluation for scores of 49 or below | Every 5 years |
| Miami (BE305)50,000+ sq ft | Retuning of building systems, starting December 2028 | Every 5 years |
| Edina25,000–49,999 sq ft | Energy assessment for buildings with savings potential | Every 5 years (next cycle 2029) |
Which programs require an audit only if you miss a target?
Building performance standards often use audits as a pathway rather than a fixed schedule. You only need one if your building falls short:
- San José: lower performers take the Improvement Pathway, which includes an ASHRAE Level II audit, retro-commissioning or qualifying upgrades.
- Chula Vista: buildings that miss their performance target complete ASHRAE retro-commissioning or a Level 2 audit by June 20, 2028.
- St. Louis: the Custom pathway follows an approved plan based on an ASHRAE Level 2 audit.
- Washington State: Tier 1 buildings above their target can use a conditional pathway that requires an investment-grade audit.
- Oregon: buildings above their target submit an energy audit and life cycle cost assessment.
Energy audit, retro-commissioning or tune-up?
Each city asks for a slightly different scope of work:
- Energy audit: a professional review of how the building uses energy, with savings measures and their costs. Most laws ask for an ASHRAE Level 2 audit.
- Retro-commissioning (RCx): testing and adjusting existing systems, such as HVAC controls, schedules and setpoints, so they run as intended.
- Tune-up or retuning: a lighter, operations-focused check and correction of the building’s main systems.
- Energy assessment: the term Berkeley, Boulder and Edina use for an audit-style review, often based on ASHRAE Standard 211.
For the difference between audit levels, read our guide to ASHRAE Level 1, 2 and 3 energy audits.
What is the compliance process?
Most audit ordinances follow the same basic steps:
- First, confirm whether your building is covered and which year your audit or tune-up is due.
- Next, gather 12 to 36 months of utility data, building drawings, equipment lists and building automation system (BAS) access.
- Then hire a qualified auditor. Cities set their own credentials, and many accept a Professional Engineer or Certified Energy Manager.
- After that, the auditor completes the site visit, trend data review and energy analysis, usually following ASHRAE Standard 211.
- Finally, file the report on the city’s form by the deadline and keep your records.
Plan aheadBook your audit 3 to 4 months before the deadline
Upcoming energy audit deadlines
Key dates to plan around:
- New York City LL87: Energy Efficiency Reports are due December 31 of your building’s assigned year.
- Los Angeles EBEWE: A/RCx is due December 1 of your assigned year.
- Philadelphia BEPP: tune-up reports follow a five-year schedule by building size, with deadlines at the end of September.
- Salt Lake City: tune-up evaluations are due December 31 of your tune-up year.
- Chula Vista: conservation requirements are due June 20, 2028.
- Miami BE305: retuning reports for the largest buildings begin December 1, 2028.
- Edina: the next energy assessment cycle is due in 2029.
What information is needed for an energy audit?
- Electricity
- Natural Gas
- Water
- District Energy
- Delivered fuels
- Building drawings
- Equipment lists
- BAS trend data
Why cities require energy audits
Benchmarking tells a city which buildings use the most energy, but it does not show how to fix them. Audit and tune-up requirements close that gap:
Find low-cost savings. Tune-ups and retro-commissioning often fix schedules, setpoints and controls that waste energy at little or no cost.
Prepare for performance standards. Audit findings give owners a roadmap of upgrades to meet future energy or emissions targets.
Energy audit compliance FAQs
Which cities require energy audits?
New York City, Los Angeles, San Francisco, Berkeley, Boulder, Atlanta, Austin, Orlando, Philadelphia, Madison, Salt Lake City, Miami and Edina all have periodic audit, assessment or tune-up rules. Several performance standards also require an audit if a building misses its target.
What ASHRAE level do audit laws require?
Most require an ASHRAE Level 2 audit, often following ASHRAE Standard 211. New York City’s Local Law 87 is the best-known example.
How often are energy audits required?
It depends on the city. Cycles range from every 4 years for tune-ups in Madison to every 10 years in New York City, Boulder and Atlanta.
Can a high ENERGY STAR score exempt my building?
In some cities, yes. Los Angeles offers an exemption for qualifying high performers, and Orlando only requires audits while a building scores below 50.
Is benchmarking the same as an energy audit?
No. Benchmarking reports a building’s energy use every year. An audit is an in-depth review of the building’s systems that identifies ways to save energy.
See also our energy benchmarking compliance guide for annual reporting rules in more than 50 cities and states, and our guide to third-party verification.
Interested in energy audit help?
Energy Audits at a Glance
- Cities with audit rules
- 13+ periodic programs
- Most common standard
- ASHRAE Level 2 / Standard 211
- Typical cycle
- Every 4 to 10 years
- Largest program
- NYC LL87, 50,000+ sq ft
- Who can perform
- Qualified auditors such as PEs and CEMs