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Local Law 97 Compliance: Is Your Building Covered?

Does Local Law 97 cover your NYC building? Size thresholds, Article 320 vs 321 pathways for rent-regulated housing, the May 1 report and penalty math.

7 min read · Updated

Local Law 97 covers a single NYC building larger than 25,000 gross square feet, or two or more buildings on one tax lot (or under one condo board) that together exceed 50,000 square feet. If you are covered, you file an emissions report certified by a registered architect or engineer every May 1 for the prior calendar year, unless your building qualifies for one of the affordable-housing or house-of-worship pathways that delay or replace the annual limits.

The figure that counts is the gross square footage in Department of Finance records, which is what the city's annual Covered Buildings List (CBL) is built from. Use the decision tree below for a first answer, then confirm on the CBL.

At a glance

Single building
Over 25,000 gross sq ft
Multiple buildings
Over 50,000 gross sq ft combined
Same tax lot, or same condo board of managers
Annual report due
May 1
Covers the previous calendar year; penalty-free grace through June 30
Late report penalty
$0.50 × gross sq ft per month
Over-limit penalty
$268 per metric ton CO₂e over the limit, per year
Article 321 penalties
$10,000 late + $10,000 non-compliance
Per building

Check whether your building is covered

You need the building's gross square footage and, for regulated housing, the share of units that are rent stabilized or rent controlled. Roofy's building pages show PLUTO floor area for each lot (see PLUTO fields explained), which is a useful starting point, but the CBL and DOF records control.

Does Local Law 97 apply to my building?

Step 1

Is any single building on the lot larger than 25,000 gross square feet?

The compliance pathways

LL97 compliance pathways on the Covered Buildings List
PathwayBuildingsWhat you must doFirst report
CP0 – Article 320Most covered buildingsMeet annual emissions limits from 2024May 1, 2025
CP1 – Article 3201 to 35% of units rent regulatedLimits delayed to 2026May 1, 2027
CP2 – Article 320Mitchell-Lama; income-restricted units via DOF exemption or HPD agreementLimits delayed to 2035May 1, 2036
CP3 – Article 321Over 35% rent regulated; project-based federal housing (Section 8 PBRA, 202, 811, Continuum of Care); HDFC co-ops; houses of worshipOne-time: 2030 limit or 13 prescriptive measuresMay 1, 2025
CP4 – City portfolioCity-owned buildings and some cultural institutionsPortfolio-wide reduction managed by DCAS and NYCHAn/a
Source: NYC DOB, Covered Buildings List matrix and Article 320 Info Guide

Exceptions in the law include certain utilities, certain garden-style apartments and most city-owned buildings (which follow the city portfolio pathway instead). If an Article 321 building's rent-regulated share later falls to 35% or less, it moves to annual Article 320 reporting. The "more than 35% rent regulated" test counts units under the Emergency Tenant Protection Act of 1974, the Rent Stabilization Law of 1969 or the 1962 rent control law.

Compliance timeline

  1. Dec 31, 2024

    Article 321 prescriptive measures deadline

    Buildings using the prescriptive pathway had to complete (or show non-applicability of) all 13 measures.
  2. 2024–2029

    First Article 320 compliance period

    Emissions limits apply to most covered buildings.
  3. May 1, 2025

    First Article 320 report and the one-time Article 321 report

    Covers calendar year 2024.
  4. 2026

    Limits begin for buildings with 1–35% rent-regulated units

  5. Each May 1

    Annual report for the prior year

    Penalty-free grace through June 30; extension requests also due by June 30.
  6. May 1, 2027

    First report for 1–35% rent-regulated buildings

  7. 2030–2034

    Stricter limits

    The law sets lower building emissions limits for this period.
  8. 2035 onward

    Lower limits continue

    Income-restricted (CP2) buildings start; first report May 1, 2036. The law aims for net zero emissions by 2050.

Filing the annual report

  • Reports are filed in the LL97 reporting portal (BEAM) and certified by a registered design professional (a licensed engineer or architect).
  • Emissions are calculated from your Energy Star Portfolio Manager benchmarking data, which you also submit under Local Law 84.
  • Extensions: requests are accepted until June 30 for two reasons: your design professional needs until August 29 to finish (for example, delayed utility data), or you have a pending Department of Finance dispute over the building's recorded square footage.
  • New buildings with a certificate of occupancy issued on or after January 1, 2023 begin reporting for the first full calendar year after the CO.
  • A bona fide purchaser who takes title during a year does not have to file for that year.

How penalties are calculated

LL97 civil penalties
ViolationFormulaExample
Article 320 report filed after June 30Gross sq ft × $0.50 per month since May 150,000 sq ft filed in early August (3 months after May 1): $75,000
Article 320 emissions over the limit(Actual – limit) tCO₂e × $268, per year100 tons over: $26,800
Article 321 report late$10,000 per building—
Article 321 non-compliance$10,000 per buildingMay be imposed annually until compliant
Source: NYC DOB, Greenhouse Gas Emissions Reductions Violations; Article 321 Filing Guide

A building that files late and is also over its limit owes both. DOB's guides describe penalty mitigation options, such as documented good faith efforts and decarbonization plans, which must be requested with the annual report. Run your own numbers with the estimator:

How much could my building be fined under Local Law 97?

Open full calculator →
Floor area by use (Portfolio Manager property type)
Annual energy use (from bills or your LL84 benchmarking report)
Estimated annual LL97 penalty (2030–2034)
$48,804
About $41 per unit per month across 100 units.
Electricity emissions145.0 tCO2e
Natural gas emissions371.8 tCO2e
Total emissions516.8 tCO2e
Building emissions limit334.7 tCO2e
Over the limit182.1 tCO2e
Cut needed to reach the limit35%
Penalty at $268 per ton over$48,804
Late-report penalty, per month$50,000
PeriodEmissionsLimitPenalty / yr
2024–2029660.7 t675.0 t$0
2030–2034516.8 t334.7 t$48,804

Estimate only. Rent-regulated and affordable buildings may follow Article 321 or a later start date, and owners may qualify for adjustments, credits or penalty mitigation. A registered design professional must certify the actual report.

What to do now

  1. Find your BBL on the CBL (DOB publishes it each year; the 2026 list reflects DOB records as of March 2026).
  2. If the listed area or pathway is wrong, file a dispute ticket in the LL97 portal with the documents DOB requires.
  3. Make sure your LL84 benchmarking is complete and accurate; it feeds the LL97 calculation.
  4. Hire a registered design professional by early in the year; DOB's extension rule looks for a contract signed by February 1.
  5. Plan upgrades around your LL87 energy audit year and track every deadline in the landlord compliance calendar.

A City Council bill introduced in January 2026 (Intro 371) would delay LL97 requirements by seven years, but as of October 2026 it is a proposal in committee, not law; plan around the current rules. Co-op and condo owners can read the shareholder view in Local Law 97 for co-op and condo owners. Questions go to DOB at [email protected].

Fact-checked October 12, 2026

Re-verified 2026-10-12. Coverage thresholds and multi-building rule (DOB LL97 page; Article 320 guide rev. 06/30/2025, 26,000 + 2 x 10,000 sq ft example), 2026 CBL reflects DOB records as of March 2026, pathways CP0-CP4 incl. Continuum of Care leases added (CBL matrix), May 1 deadline, grace through June 30, extension reasons and Aug 29 date, Feb 1 RDP contract, new-building CO/TCO and bona fide purchaser rules (Article 320 guide pp.17-18), penalties $0.50/sf per month since May 1 and $268/tCO2e (DOB violations page), Article 321 $10,000 late + $10,000 non-compliance, may be imposed annually, Dec 31 2024 PECM deadline, loss of 321 status (321 filing guide). Penalty example checked: 50,000 x $0.50 x 3 = $75,000. Int 0371-2026 status (in committee, no hearing or vote) from NYC Council Legistar. Emissions intensity limits not reproduced (vary by property type; 1 RCNY 103-14).

Sources

  1. LL97 Greenhouse Gas Emissions Reductions · NYC Department of Buildings (accessed October 12, 2026)
  2. Greenhouse Gas Emissions Reductions: Violations · NYC Department of Buildings (accessed October 12, 2026)
  3. Article 320 Info Guide (rev. 06/30/2025) · NYC Department of Buildings (accessed October 12, 2026)
  4. Article 321 Filing Guide · NYC Department of Buildings (accessed October 12, 2026)
  5. Int 0371-2026: delaying Local Law 97 requirements by 7 years (bill status) · New York City Council (accessed October 12, 2026)
  6. Covered Buildings List compliance pathway matrix · NYC Department of Buildings (accessed October 12, 2026)

General information, not legal, tax or financial advice. Rules change; confirm with the agency or a professional before you act.

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