Local Law 87 Deadlines
Complete filing schedule for NYC energy audit and retro-commissioning requirements. Deadlines by block number, 10-year compliance cycle, DOB NOW filing process, penalties for non-compliance, and the connection to Local Law 97.
When are Local Law 87 deadlines due?
Local Law 87 deadlines follow a rolling 10-year cycle based on the last digit of a building's tax block number. Each year, buildings with a specific block-number digit must file their energy audit and retro-commissioning reports with the NYC Department of Buildings (DOB).
The current compliance cycle (Cycle 4) runs from 2023 through 2032. Building owners should identify their tax block number and determine their filing year using the schedule below. The filing deadline is December 31 of the designated year.
- Applies to: Buildings over 50,000 gross square feet in New York City
- Required filings: ASHRAE Level II energy audit + retro-commissioning (RCx) study
- Filing method: DOB NOW portal
- Performed by: Licensed Professional Engineer (PE) or Registered Architect (RA)
What is the LL87 filing schedule by block number?
The LL87 filing schedule assigns each building a deadline year based on the last digit of its tax block number — digit 3 filed in 2023, digit 4 in 2024, and so on through digit 0 (or 10) in 2032 — with a December 31 deadline each year.
| Last Digit of Block # | Cycle 4 Deadline | Status (as of 2026) |
|---|---|---|
| 3 | December 31, 2023 | Past due |
| 4 | December 31, 2024 | Past due |
| 5 | December 31, 2025 | Past due |
| 6 | December 31, 2026 | Due this year |
| 7 | December 31, 2027 | Upcoming |
| 8 | December 31, 2028 | Upcoming |
| 9 | December 31, 2029 | Upcoming |
| 0 | December 31, 2030 | Upcoming |
| 1 | December 31, 2031 | Upcoming |
| 2 | December 31, 2032 | Upcoming |
Find your tax block number on your property tax bill (Form RPIE), in DOB NOW, or on the NYC ZoLa map.
How do I file LL87 through DOB NOW?
LL87 filings are submitted through the DOB NOW portal in five steps — register the building, engage a qualified professional, upload the energy audit and RCx reports, pay the filing fee, and submit for DOB review.
- Register on DOB NOW — create an account (or log in) and verify your building ownership or authorized representative status
- Engage a qualified professional — hire a licensed Professional Engineer (PE) or Registered Architect (RA) to perform the ASHRAE Level II energy audit and retro-commissioning study
- Complete the audit and RCx — the PE/RA conducts the on-site energy audit, identifies Energy Conservation Measures (ECMs), and performs the retro-commissioning assessment
- Upload reports to DOB NOW — submit the energy audit report and RCx report through the Sustainability Compliance section of DOB NOW, including all required data fields
- Pay and submit — pay the filing fee and submit for DOB review. You will receive a confirmation number and can track the filing status online
Allow 3–6 months for the audit and RCx process. Start well before your December 31 deadline to avoid penalties for late filing.
What are the penalties for missing LL87 deadlines?
Missing your LL87 filing deadline triggers a $5,000 annual penalty from the NYC Department of Buildings, with additional fines accruing each year the building remains non-compliant — plus violations that appear on the building's public DOB record and can affect property transactions.
| Violation | Penalty |
|---|---|
| Failure to file energy audit | $5,000 per year |
| Failure to file retro-commissioning report | $5,000 per year |
| Submitting false or misleading information | Up to $50,000 + criminal penalties |
Beyond financial penalties, non-compliance creates a DOB violation on public record. This can complicate property sales, refinancing, and insurance renewals. Some lenders now require LL87 compliance verification as part of due diligence.
How does LL87 relate to Local Law 97?
Local Law 87 and Local Law 97 are complementary — LL87 identifies energy waste through audits and retro-commissioning, while LL97 sets carbon emission caps and penalizes buildings that exceed them — making LL87 audit results the roadmap for meeting LL97 targets.
| Aspect | Local Law 87 | Local Law 97 |
|---|---|---|
| Purpose | Identify energy efficiency improvements | Reduce building carbon emissions |
| Frequency | Every 10 years (by block number) | Annual reporting, caps tighten in 2030 |
| Threshold | Buildings over 50,000 sq ft | Buildings over 25,000 sq ft |
| Penalties | $5,000/year for non-filing | $268/ton CO₂ over the cap |
Smart building owners align their LL87 audit cycle with their LL97 compliance planning. The Energy Conservation Measures (ECMs) identified in the LL87 audit often form the basis of the capital improvement plan needed to meet LL97 emission caps by 2030.
What records should building owners maintain for LL87?
Building owners should maintain six categories of LL87 records — the original audit and RCx reports, DOB filing confirmations, ECM implementation documentation, utility data used in the audit, professional credentials, and correspondence with the DOB — for at least 10 years until the next compliance cycle.
- Audit and RCx reports — complete copies of both the ASHRAE Level II energy audit and retro-commissioning report as submitted to DOB
- DOB filing confirmation — submission confirmation number, filing receipt, and any DOB correspondence regarding the filing
- ECM implementation records — documentation of any Energy Conservation Measures implemented as a result of the audit, including costs, contractors, and energy savings
- Utility data — at least 12 months of utility bills (electric, gas, steam, oil) used as input for the energy audit
- Professional credentials — PE/RA license information for the professional who performed the audit and RCx
These records serve as evidence of compliance during DOB audits, property transactions, and insurance reviews. Digital records with organized filing are strongly recommended.
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Frequently Asked Questions
When is my Local Law 87 filing due?
Your LL87 filing deadline depends on the last digit of your property's tax block number. Each digit corresponds to a specific year within the rolling 10-year compliance cycle. Check the block number on your property tax bill or in DOB NOW and match it to the schedule table above. For Cycle 4, buildings with block numbers ending in 3 or 4 filed in 2023-2024, while those ending in 9 or 0 are due in 2029-2030.
What happens if I miss my LL87 deadline?
Missing your LL87 filing deadline results in penalties from the NYC Department of Buildings. The initial penalty is $5,000 per year for non-compliance. Additional penalties can accrue for continued failure to file. The DOB may also issue violations that appear on your building's public record, which can affect property transactions and financing.
Can I get an extension on my LL87 deadline?
The DOB may grant extensions in limited circumstances, such as when a building is undergoing major renovation or when the energy audit reveals conditions that require additional time to assess. Extension requests must be filed through DOB NOW before the original deadline. Extensions are not guaranteed and are evaluated on a case-by-case basis.
Do all NYC buildings need to comply with LL87?
Local Law 87 applies to buildings over 50,000 gross square feet in New York City. This includes individual buildings over 50,000 sq ft and multiple buildings on a single tax lot that together exceed 50,000 sq ft. Residential buildings, commercial buildings, and mixed-use buildings are all subject to LL87 if they meet the size threshold.
What is the difference between LL87 and LL97?
Local Law 87 requires energy audits and retro-commissioning on a 10-year cycle to identify energy efficiency improvements. Local Law 97 sets carbon emission caps and penalizes buildings that exceed them starting in 2024. The two laws are complementary — LL87 audits often identify the improvements needed to meet LL97 emission caps. Many building owners use their LL87 audit results to develop their LL97 compliance strategy.
Related Compliance Guides
Local Law 87 — Energy Audit Guide
Complete guide to LL87 energy audits and retro-commissioning requirements.
Local Law 97 — Carbon Emission Caps
NYC carbon emission limits, penalties, and compliance strategies.
Local Law 97 Penalties
Penalty calculation, enforcement timeline, and avoidance strategies for LL97.
NYC Compliance Calendar
All 2026 NYC building compliance deadlines in one place.
Never Miss a Compliance Deadline
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