NYC Local Law 97: Building Emissions Reports and DOB Filings

Buildings produce over two-thirds of New York City’s greenhouse gas emissions. Local Law 97 of 2019 (as amended), part of the Climate Mobilization Act, sets greenhouse gas emissions limits for most large buildings. The limits began in 2024, and stricter limits take effect in 2030. The City’s stated goal is to cut emissions from its largest buildings 40 percent by 2030 and to reach net zero by 2050. The Department of Buildings (DOB) Sustainability Bureau administers the law.

Which buildings are covered

DOB uses Department of Finance records for building size. LL97 covers:

  • a building that exceeds 25,000 gross square feet
  • two or more buildings on the same tax lot that together exceed 50,000 gross square feet
  • two or more condominium buildings governed by the same board of managers that together exceed 50,000 gross square feet

Compliance applies to each building (BIN) on a tax lot (BBL) that meets the threshold, alone or together with the others.

DOB publishes a Covered Buildings List (CBL) each filing year. The 2026 list was published in March 2026. Owners are responsible for checking it. If your building’s information or compliance pathway is wrong, you dispute it with a CBL Dispute ticket in the LL97 Reporting Portal (BEAM). Being left off the list doesn’t relieve an owner of the law.

Two articles, different pathways

  • Article 320 covers most private buildings (rule: 1 RCNY §103-14). Buildings report annual emissions against their limits. Depending on the building, compliance under Article 320 begins in 2024, 2026 or 2035.
  • Article 321 covers certain affordable housing and houses of worship (rule: 1 RCNY §103-17). These buildings demonstrate compliance once, through a report of compliance.

What the filings involve

  • The annual report. Article 320 buildings file a report with DOB detailing their annual greenhouse gas emissions. The first was due by May 1, 2025, and one is due by May 1 of every year after. The report must be certified by a registered design professional (in limited cases, a retro-commissioning agent).
  • Where it’s filed. Reports go through the LL97 Reporting Portal (BEAM, nyc.beam-portal.org), using energy data from ENERGY STAR Portfolio Manager. Filing fees, extensions and adjustments are paid in DOB NOW: Safety.
  • Extensions. DOB’s rule lets owners apply to extend the reporting deadline. For filing year 2026, DOB’s notice said compliance reports were due by May 1 and no later than June 30, 2026, and that owners could apply by June 30 to extend to August 29, 2026. No professional attestation was needed to apply for the extension (DOB service notice, February 27, 2026).
  • Adjustments, deductions and disputes. These are separate requests filed through the portal: adjustments for financial constraints (§320.7), deductions such as Affordable Housing Reinvestment Fund offsets (capped at 10 percent of the emissions limit) and distributed energy resources, and CBL disputes. Each has its own DOB user guide.

DOB enforces LL97 through violations; see DOB’s LL97 violations page for details.

How S & M Expediting helps

S & M Expediting is a Class 2 filing representative and NYC-certified M/WBE, with more than 75 years of combined NYC expediting experience. On Local Law 97, our role is the filing and DOB submission work:

  • check whether the building is on the Covered Buildings List and which pathway DOB shows, and prepare a CBL dispute ticket when the record is wrong
  • set up and track the building’s submissions in the LL97 Reporting Portal and DOB NOW: Safety: the annual report, extension requests, and the filing-fee payments
  • coordinate with your registered design professional, who prepares and certifies the emissions report, so it is submitted on time

What we don’t do: we don’t perform energy audits or engineering, and we don’t certify LL97 reports. A registered design professional certifies the report. If your building also files Local Law 84 benchmarking or Local Law 87 reports, we can keep those filings on the same calendar.

Who does any upgrade work

We will work with the contractor you have, or if not, we will recommend one from our network. Your registered design professional decides what upgrade work, if any, the building needs. Work that needs DOB permits goes through our permit filing service.

Contact us with the building address to check its LL97 status.