Washington Clean Buildings Performance Standard (CBPS)
What is Washington's Clean Buildings Performance Standard?
Washington State’s Clean Buildings Performance Standard (CBPS), created by the Clean Buildings Act (HB 1257, expanded by SB 5722), requires owners of larger commercial and multifamily buildings to benchmark their energy use, manage it, and, for the largest buildings, meet an energy use intensity (EUI) target. The Department of Commerce runs the program.
CBPS has two tiers:
- Tier 1 (commercial over 50,000 sq ft) must meet an EUI target or an approved conditional pathway, adopt an energy management plan and an operations and maintenance program, and report on a phased schedule from 2026 to 2028.
- Tier 2 (commercial over 20,000 up to 50,000 sq ft, and multifamily over 20,000 sq ft) must benchmark and adopt an energy management plan and O&M program, reporting by July 1, 2027.
Commerce released the 2026 edition of the CBPS Integrated Document in August 2026, so it is a good time to review your plan.
What buildings must comply with Washington CBPS?
- Tier 1: buildings where non-residential, hotel, motel and dormitory floor area exceeds 50,000 sq ft (excluding parking)
- Tier 2: commercial buildings over 20,000 up to 50,000 sq ft, and multifamily residential buildings over 20,000 sq ft
Some buildings may qualify for an exemption, such as those that are unoccupied, under financial distress, scheduled for demolition, or used primarily for manufacturing or agriculture. Commerce has proposed new pathways and exemptions, so check the latest rules before you apply.
What is the penalty for non-compliance?
Commerce enforces CBPS through a two-step notice process:
- Notice of Violation and Opportunity to Correct: Commerce first gives you a chance to fix the problem.
- Notice of Intent to Assess Penalties: if the issue is not resolved, Tier 1 penalties can reach $5,000 plus $1.50 per square foot of gross floor area.
- Mitigation plan: responding with a non-compliance mitigation plan can reduce the penalty.
Owners can request an extension of up to six months before or after their deadline once Commerce finalizes its extension rules.
What is the compliance process?
CBPS reporting uses ENERGY STAR Portfolio Manager together with the Commerce compliance portal. A typical Tier 1 filing looks like this:
- First, confirm your tier and deadline using your Commerce notification letter and Building ID.
- Next, benchmark at least 12 months of whole-building energy data in Portfolio Manager.
- Then compare your weather-normalized EUI with your EUI target, and plan upgrades or a conditional compliance pathway if you are above it.
- Adopt an energy management plan and an operations and maintenance program.
- Finally, submit your compliance report to Commerce by your deadline. Tier 2 buildings follow the same steps without the EUI target.
What are the Washington Clean Buildings deadlines?
Tier 1 deadlines are phased by building size, all on June 1. Tier 2 buildings report once, by July 1, 2027.
Next deadlineJune 1, 2027 for Tier 1 buildings of 90,001–220,000 sq ft
The first Tier 1 deadline (June 1, 2026, for buildings over 220,000 sq ft) has passed, and Tier 1 buildings report again every five years. Early adopter incentives remain available for owners who improve before their deadline.
Washington Clean Buildings deadlines by tier and size
Here is when each group must report under the Clean Buildings Performance Standard:
| Tier and size | What is required | Deadline |
|---|---|---|
| Tier 1: over 220,000 sq ftPassed | EUI target, energy management plan, O&M program | June 1, 2026 |
| Tier 1: 90,001–220,000 sq ftNext | EUI target, energy management plan, O&M program | June 1, 2027 |
| Tier 1: 50,001–90,000 sq ft | EUI target, energy management plan, O&M program | June 1, 2028 |
| Tier 2: commercial 20,001–50,000 sq ft; multifamily 20,000+ sq ft | Benchmarking, energy management plan, O&M program | July 1, 2027 |
What utilities are required for benchmarking reporting?
- Electricity
- Natural Gas
- District Energy
- Any other purchased fuel
What is the purpose of the Clean Buildings Performance Standard?
Buildings are one of Washington’s largest sources of greenhouse gas emissions, so the State uses CBPS to make existing buildings more efficient. The standard serves two main goals:
Cut energy use and emissions. EUI targets push the least efficient large buildings to improve, while energy management plans keep savings in place.
Build better operating habits. Benchmarking and O&M programs help owners understand and control energy use. Many owners then go further and pursue ENERGY STAR certification.
Seattle owners also have city rules to follow; see our Seattle energy benchmarking guide or our energy benchmarking compliance guide.
This program includes an energy audit, assessment or tune-up requirement. Compare it with other cities in our energy audit compliance guide.
Washington Clean Buildings FAQs
Does my multifamily building need to comply with CBPS?
Yes, if it is over 20,000 sq ft. Multifamily buildings are Tier 2, so they must benchmark and adopt an energy management plan and O&M program by July 1, 2027, but they do not have an EUI target.
What happens if my building is above its EUI target?
Tier 1 buildings above their target can follow a conditional compliance pathway, which requires an investment-grade audit and cost-effective energy efficiency measures.
How much are CBPS penalties?
For Tier 1, penalties can reach $5,000 plus $1.50 per square foot of gross floor area, after Commerce gives you a chance to correct the issue.
Do Seattle buildings also have to follow city rules?
Yes. Seattle buildings must also meet the City’s benchmarking ordinance and Building Emissions Performance Standard. See our Seattle guide for details.
Can Energy Fave help with Clean Buildings compliance?
Yes. Energy Fave can benchmark your building, compare it with its EUI target, prepare your energy management plan and O&M program, and file your report.
Interested in benchmarking help?
Clean Buildings at a Glance
- Who's covered
- Commercial 20,000+ sq ft; multifamily 20,000+ sq ft
- Next Tier 1 deadline
- June 1, 2027 (90,001–220,000 sq ft)
- Tier 2 deadline
- July 1, 2027
- Tier 1 penalty
- Up to $5,000 + $1.50/sq ft
- Reporting tool
- Portfolio Manager + Commerce portal