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If you own a private building of 50,000 square feet or more in the District, BEPS covers it now. For buildings below their standard, Cycle 1 ends December 31, 2026. Every privately owned building of 10,000 square feet or more owes third-party-verified 2026 energy data in May 2027. Private buildings of 25,000 square feet or more join when Cycle 2 begins, set for January 1, 2029 by the FY2027 Budget Support Act.
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BEPS · D.C. Code § 8-1772.21
What are DC's Building Energy Performance Standards?
DC's Building Energy Performance Standards come from the CleanEnergy DC Omnibus Amendment Act of 2018 (D.C. Code § 8-1772.21). Every covered building benchmarks its energy use each year in ENERGY STAR Portfolio Manager. A building below its property type's standard is placed in a compliance cycle and must improve through one of DOEE's pathways by the end of the cycle. The Department of Energy and Environment (DOEE) runs the program.
- 50,000 sq ft
- Privately owned buildings this size or larger are covered in Cycle 1; those below their standard on 2019 data must complete a pathway by December 31, 2026, unless DOEE approved a delay of compliance or a multi-cycle alternative pathway. District-owned buildings are covered from 10,000 sq ft. D.C. Code § 8-1772.21
- Jan 1, 2029
- Cycle 2 is set to begin, and privately owned buildings of 25,000 sq ft or more to join, a year later than before under the FY2027 Budget Support Act (the emergency act applies from October 1, 2026; the permanent act takes effect after the congressional review every DC law goes through). D.C. Act 26-416 · D.C. Act 26-418
- Median
- Most 2021 standards are the District median ENERGY STAR score for the property type (or source EUI where there is no score), from 2019 data; types with fewer than 10 DC buildings use the national median. Office 71, multifamily 66. D.C. Code § 8-1772.21 · 20 DCMR 3530 · Guide to the 2021 BEPS
- 20%
- The Performance Pathway: cut site energy use intensity by more than 20% in 2026, against the 2018 to 2019 average, measured as DOEE's Adjusted Site EUI for property types with an ENERGY STAR score. DOEE Guidebook v1.2
- $7.5M
- The cap on the one-time payment for missing a pathway: up to $10 per square foot, reduced in proportion to progress. 20 DCMR 3521 · Guidebook v1.2 §7.1
D.C. Code § 8-1772.21Department of Energy and Environment (DOEE)
Coverage
Am I covered?
BEPS covers privately owned buildings of 50,000 square feet or more today, and District-owned buildings of 10,000 square feet or more. Privately owned buildings of 25,000 square feet join when Cycle 2 begins, set for January 1, 2029, and 10,000 square feet in Cycle 3, set for January 1, 2035. Floor area is Portfolio Manager gross floor area less parking, and structures that share systems or a meter count together. D.C. Code § 8-1772.21 · D.C. Acts 26-416 and 26-418 · 20 DCMR 3513
Not covered
- Buildings outside the District, in Maryland or Virginia
- Energy requirements for a building that met its standard, for the rest of that cycle (it still benchmarks and is re-evaluated)
- New buildings with a Certificate of Occupancy between January 2, 2021 and December 31, 2026; they are evaluated at the next cycle
- Buildings DOEE exempts for demolition, financial distress, or low occupancy in either of the two years before the cycle
Worth knowing
Historic designation does not exempt a building, and neither does a sale: the owner at the end of the cycle is responsible. Buildings that meet DOEE's qualifying affordable housing test (at least half the units at 50% of area median income or less, or a limited-equity co-op) can request an extended delay; DOEE approves only delays of exactly one cycle.
The clock
Key deadlines
Passed
Cycle 1 begins
DOEE set the first standards. Private buildings of 50,000 sq ft or more and District-owned buildings of 10,000 or more that fell below them on 2019 data, or filed no 2019 report, entered Cycle 1. DOEE · D.C. Code § 8-1772.21
Passed
Annual benchmarking
Calendar-2025 data, the first report for privately owned buildings of 10,000 to 24,999 sq ft. DOEE help center · D.C. Code § 6-1451.03
Next deadline · 108 days
Cycle 1 ends
The last day of the cycle, and the last day to submit a Custom Alternative Compliance Pathway proposal. DOEE Guidebook v1.2 §4.6.1
What happens if you miss itCycle 1 final reports
Cycle 1 closeout: the third-party-verified 2026 benchmarking report and the Completed Actions Report for the Performance and Standard Target pathways, and the Evaluation, Monitoring, and Verification Report for the Prescriptive pathway. DOEE moved it from May 1, a Saturday. DOEE Guidebook v1.2, Tables 4, 6 and 7
Cycle 2 begins
DOEE must set new standards by this date, and privately owned buildings of 25,000 sq ft or more join. The FY2027 Budget Support Act moves this from January 1, 2028 (the emergency act applies from October 1, 2026; the permanent act takes effect after congressional review). D.C. Act 26-416 · D.C. Act 26-418
Cycle 3 begins
Privately owned buildings of 10,000 sq ft or more join, moved from 2034 by the same act. D.C. Act 26-416 · D.C. Act 26-418
Compliance
How to comply
Cycle 1 buildings chose a pathway by April 3, 2023; DOEE assigns one to a building that does not. For Cycle 2 the law adds a trajectory pathway with building-specific targets; DOEE has not published Cycle 2 standards or deadlines yet.
- 01
Performance
Cut site energy use intensity by more than 20% in 2026, compared with the 2018 to 2019 average. DOEE measures it as Adjusted Site EUI for property types with an ENERGY STAR score, and weather-normalized site EUI for the rest. Open to every property type. DOEE Guidebook v1.2 §3.1
- 02
Standard Target
For property types whose standard is at least the national median (an ENERGY STAR score of 50), such as office, multifamily, hotel and retail: meet or beat your standard in 2026. DOEE Guidebook v1.2 §3.2
- 03
Prescriptive
Complete an energy audit, an action plan and approved efficiency measures, then verify them. The building complies once the measures are done and reported, whatever its energy result. The law names it only for Cycle 1; whether DOEE offers it in Cycle 2 depends on future rules. Guidebook v1.2 §3.3 · D.C. Code § 8-1772.21
- 04
Alternative Compliance Pathway
For unique situations: deep retrofits over two or three cycles (for affordable, rent-controlled, campus, residential condominium and co-op, and COVID-distressed buildings), new construction, a change of property type, an adjusted baseline, or a campus. Custom proposals are due by December 31, 2026 and must name a backup pathway. DOEE Guidebook v1.2 ch. 4
We map each building to the path and dates that apply to it.
Enforcement
Penalties
The payment comes once, at the end of the cycle, and shrinks with the progress a building makes.
- Missing the pathway: an alternative compliance payment of up to $10 per square foot, capped at $7.5 million per building, or per campus for colleges and hospitals.
- Progress reduces it: on the Performance Pathway, a 10% cut in site EUI halves the maximum. Missing or knowingly inaccurate data can bring the full maximum.
- Civil fines: $500 for each missed report, $1,000 for not selecting a pathway, $2,000 for a measure that threatens health and safety, higher for repeat offenses.
- Late benchmarking: up to $100 for each day a report is late.
- If DOEE agrees, a settlement can put the payment into efficiency work instead. If the project costs 120% or more of the payment, nothing is paid to DOEE. It must be requested before the notice of infraction.
20 DCMR 3521 · 16 DCMR 4018 · Guidebook v1.2 §7 · D.C. Code § 6-1451.03
Questions
What owners ask
Is my building covered by DC BEPS?
Cycle 1 covers privately owned buildings of 50,000 square feet or more, and District-owned buildings of 10,000 or more. Privately owned buildings of 25,000 square feet or more join when Cycle 2 begins, set for January 1, 2029, and 10,000 square feet or more in Cycle 3, set for January 1, 2035. A building that met its standard has no BEPS requirement for the rest of that cycle.
When does Cycle 2 start?
It is set for January 1, 2029. The Council's FY2027 Budget Support Act moved it from January 1, 2028: the emergency act applies from October 1, 2026 and lasts no more than 90 days, and the permanent act (D.C. Act 26-418) takes effect only after the congressional review every DC law goes through. DOEE's Guidebook v1.2 (August 11, 2026) and its online timeline still show 2028, and the online D.C. Code linked on this page will show 2028 until the change is codified. DOEE has not published Cycle 2 standards or deadlines yet.
When is benchmarking due?
Every May 1, for the previous calendar year, in ENERGY STAR Portfolio Manager. Every privately owned building of 10,000 square feet or more must report, and 2026 data must be verified by a third party in 2027.
How do I find out whether my building meets its standard?
Look it up in DOEE's Building Energy Performance disclosure on DC Open Data (the MEETS_BEPS field) or in DOEE's Building Owner Portal. The disclosure lists every building covered in the first BEPS period: private ones of 50,000 sq ft and up, District-owned ones of 10,000 and up.
What if my building does not meet its standard?
It is placed in the compliance cycle. In Cycle 1 you choose a pathway (Performance, Standard Target, Prescriptive, or an approved Alternative Compliance Pathway) and complete it by the end of the cycle. If you do not choose, DOEE assigns one.
What does not complying cost?
A one-time alternative compliance payment at the end of the cycle, up to $10 per square foot and capped at $7.5 million per building, reduced in proportion to the progress made. Separate fines start at $500 for each missed report, and late benchmarking costs up to $100 a day.
Is affordable housing treated differently?
Buildings that meet DOEE's qualifying affordable housing test (at least half the units at 50% of area median income or less, or a limited-equity co-op) can request an extended delay, which DOEE approves only for exactly one cycle. The Affordable Housing Retrofit Accelerator, which uses the broader statutory definition (80% of area median income), offers technical and financial help to qualifying multifamily buildings that miss BEPS.
Is this DOEE?
No. Vert Energy Group is a private company and is not affiliated with the District or DOEE. DOEE and the D.C. Code are the authority; this page summarizes them and cites its sources.
Private BEPS compliance help from Vert Energy Group
Let someone who has read D.C. Code § 8-1772.21 handle it.
Vert maps your buildings against the DC standards, tells you what is due and when, and shows you what compliance will cost before you commit to anything.
