DC Energy Benchmarking Law & BEPS
What is the DC Energy Benchmarking Law?
The DC Energy Benchmarking Law, part of the Clean and Affordable Energy Act of 2008 and expanded by the Clean Energy DC Omnibus Act of 2018, requires owners of private buildings of 10,000 square feet or more to benchmark their energy and water use every year and report it to the Department of Energy and Environment (DOEE).
Benchmarking also drives DC’s Building Energy Performance Standards (BEPS). Buildings over 50,000 sq ft that score below the median for their property type must improve within each compliance cycle or face penalties. Cycle 1 ends on December 31, 2026, which makes 2027 a critical year for DC owners.
DOEE publishes benchmarking results, so tenants, buyers and lenders can compare buildings across the District.
What buildings must comply with DC energy benchmarking?
The requirement has been phased in by building size:
- Private buildings over 50,000 sq ft: benchmarking since 2014, and subject to BEPS
- Private buildings of 25,000–49,999 sq ft: benchmarking since 2022
- Private buildings of 10,000–24,999 sq ft: benchmarking since 2025 (covering 2024 data)
- District government buildings over 10,000 sq ft
Your building may qualify for an exemption if it was unoccupied (on average, fewer than 40 person-hours per week, excluding security, janitorial and maintenance staff), if disclosure would harm national security, or if it is new construction that received its certificate of occupancy during the reporting year.
What is the penalty for non-compliance?
DC enforces both benchmarking and BEPS with fines:
- Missed benchmarking report: fines of up to $100 per day for owners. Non-residential tenants who fail to give owners their energy and water data can be fined the same amount.
- BEPS non-compliance: up to $10 per square foot of gross floor area.
- BEPS cap: no building pays more than $7,500,000.
For BEPS, DOEE reduces the penalty in proportion to the progress a building has made toward its target.
What is the compliance process?
DC owners benchmark in ENERGY STAR Portfolio Manager and submit through DOEE. A typical filing looks like this:
- First, confirm your building’s DC Real Property Unique ID and its coverage on DOEE’s covered buildings list.
- Next, set up or update the property in Portfolio Manager with accurate floor area and use details.
- Then enter 12 months of whole-building energy and water data. Request aggregated data from Pepco, Washington Gas and DC Water where tenants are separately metered.
- In verification years, have a licensed third-party professional verify your data before you submit.
- Finally, submit the report to DOEE through Portfolio Manager by the deadline, and keep the confirmation.
What is the deadline for DC energy benchmarking?
DC benchmarking reports are due each spring and cover the previous calendar year. For 2025 data, the deadline was May 1, 2026. Because May 1, 2027 falls on a Saturday, reports for 2026 data are due the following Monday.
Next deadlineMay 3, 2027 for calendar-year 2026 data
Third-party verification: DOEE requires verification by a licensed professional every six years, and 2027 (covering 2026 data) is a verification year. In addition, BEPS buildings that did not meet their standard must file their Completed Actions Report by the same date.
DC benchmarking and BEPS at a glance
Benchmarking and BEPS work together in DC. Here is how the requirements and dates line up:
| Requirement | Who must comply | Key dates |
|---|---|---|
| Annual benchmarkingEvery year | Private buildings 10,000+ sq ft; District buildings 10,000+ sq ft | May 3, 2027 for 2026 data |
| Third-party verificationEvery 6 years | Covered buildings in verification years | 2027 filing (2026 data) |
| BEPS Cycle 1Ends 2026 | Private buildings over 50,000 sq ft below the median | Ends Dec 31, 2026; delay or exemption requests due April 1, 2027 |
| BEPS Cycle 2Next cycle | Buildings over 50,000 sq ft; smaller buildings later | Standards set by Jan 1, 2029 |
Need more time? Most BEPS owners can request a delay of up to three years, and qualified affordable housing may receive longer. Owners can also apply for a full-cycle exemption in cases such as demolition, low occupancy or financial distress.
What utilities are required for benchmarking reporting?
- Water
- Electricity
- Natural Gas
- District Energy
- Any other purchased fuel
What is the purpose of DC's benchmarking law?
Buildings produce most of the District’s greenhouse gas emissions, so DC uses benchmarking and BEPS to measure and improve how they perform. The law serves two main goals:
Cut energy use and emissions. Annual data shows owners where they waste energy, and BEPS requires the lowest performers to improve, which supports the District’s goal of carbon neutrality by 2045.
Make performance transparent. Because DOEE publishes the results, tenants and buyers can compare buildings, and owners have a clear reason to improve. Many owners then go further and pursue ENERGY STAR certification.
To see how other cities handle benchmarking, visit our energy benchmarking compliance guide.
See our guides for Maryland BEPS, Montgomery County and Philadelphia, or our full energy benchmarking compliance guide.
Need a verifier? Our Professional Engineers and Certified Energy Managers provide third-party verification services.
DC energy benchmarking FAQs
Do buildings between 10,000 and 25,000 sq ft have to benchmark in DC?
Yes. Since 2025, private buildings of 10,000–24,999 sq ft must benchmark every year. They are not yet subject to BEPS performance targets.
What happens when BEPS Cycle 1 ends?
Buildings that did not meet their standard must show they completed their chosen pathway. DOEE expects Completed Actions Reports and verified 2026 benchmarking data by May 3, 2027.
How much are DC BEPS penalties?
Up to $10 per square foot of gross floor area, capped at $7.5 million per building, reduced in proportion to the progress a building has made.
Do tenants have to share data with owners?
Yes. Non-residential tenants must provide the energy and water data owners need to benchmark, and they can be fined for failing to do so.
Can Energy Fave handle my DC benchmarking and verification?
Yes. Energy Fave can collect the utility data, coordinate third-party verification, and submit your report to DOEE on your behalf.
Interested in benchmarking help?
DC at a Glance
- Who's covered
- Private buildings 10,000+ sq ft
- Next deadline
- May 3, 2027The 2026 report was due May 1, 2026. Not filed yet? We can file it now →
- Benchmarking fine
- Up to $100 per day
- BEPS penalty
- Up to $10/sq ft, capped at $7.5M
- Verification
- Third-party, every 6 years (2027 is one)