Washington DC Building Energy Benchmarking & Performance Standards (BEPS)

Who's covered

Two obligations share the "BEPS" name in DC, and understanding them as separate is the whole point of this page:

1. Benchmarking -- the baseline, annual requirement to report energy use to the District Department of Energy & Environment (DOEE), currently covering buildings 10,000 sq ft and larger.
2. The Building Energy Performance Standard proper -- a performance requirement layered on top of benchmarking data, applying (in its first cycle) to a narrower population and forcing underperforming buildings to actually improve, not just report.

The benchmarking threshold has phased down over time, and it's still moving relatively recently by this registry's standards. DC's own materials describe the sequence as: all privately-owned buildings over 25,000 sq ft required to benchmark by April 1, 2022, then all privately-owned buildings over 10,000 sq ft required to benchmark by May 1, 2026. If your building is in the newly-added 10,000-25,000 sq ft band, its very first benchmarking report was due earlier this year -- this isn't a future obligation for that cohort, it's a very recent one. We don't have a precisely confirmed year for the threshold's original, higher starting point (DC's benchmarking mandate traces back further than the 25,000 sq ft figure above), so we're not asserting one here rather than guessing.

BEPS's first compliance cycle, separately, applies to private buildings larger than 50,000 sq ft and DC-owned buildings larger than 10,000 sq ft -- a materially higher bar than the current benchmarking threshold. As benchmarking's own threshold has ratcheted down over time, DOEE has been folding more buildings into BEPS accordingly, so expect that gap to narrow in later cycles rather than assume it's fixed at 50,000 sq ft indefinitely.

Key dates

May 1, every year, for the prior calendar year -- codified directly in DC Code § 6-1451.03: benchmark and ENERGY STAR statements of energy performance "shall be made available to DOEE by May 1 of the respective following year." 2024 had a one-time exception, with a July 1 deadline instead.

Third-party verification of benchmarking data is required in 2024, 2027, and every 6 years after that -- this is a corrected reading worth flagging explicitly, because older secondary sources (and an earlier version of our own program survey) describe this as a flat 3-year cycle starting with CY2023 data. The statute itself is specific about the actual years, and they are not evenly spaced on a simple 3-year cadence.

BEPS itself runs on 6-year compliance cycles, with Cycle 1 ending December 31, 2026 -- meaning covered buildings are, as of this guide's last verification, in the final months of their first BEPS performance period.

Benchmarking vs. BEPS -- two different obligations

It's easy to read "BEPS" as one thing because DC uses the acronym broadly, but the two layers have genuinely different mechanics, populations, and consequences:

	Benchmarking	BEPS (performance standard)
What it requires	Report annual energy use via ESPM	Actually improve energy performance against a target
Current threshold	10,000 sq ft (phased down from 50,000, then 25,000)	50,000+ sq ft private (first cycle); DC-owned 10,000+ sq ft
Cadence	Annual, due May 1	6-year compliance cycles (Cycle 1 ends Dec 31, 2026)
Verification	Third-party, in 2024, 2027, and every 6 years thereafter	Tied to Compliance Pathway completion within the cycle
Penalty	Up to $100/day for non-submission	Up to $10/sq ft, capped at $7,500,000, via Alternative Compliance Payment

BEPS compliance itself isn't a single fixed target across every building. DOEE offers a Performance Pathway (a numeric improvement target specific to the building's use type -- for example, office buildings on the Performance Pathway work against a 20% Adjusted Site EUI improvement requirement) and other compliance pathways defined in DOEE's Compliance Regulations. We're not attempting to reproduce every building-type's specific target here, since they're granular and pathway-specific -- the structural point every covered owner should plan around is that BEPS asks for a real, measured improvement against a pathway target, not just a report.

Penalties

Benchmarking non-compliance: up to $100 per day during which the required submission hasn't been made, with civil infraction sanctions available as an alternative enforcement route.

BEPS non-compliance is a different order of magnitude. A building that fails to fully implement its Compliance Pathway's energy performance requirements by the end of its Compliance Cycle owes an Alternative Compliance Payment -- up to $10 per square foot of gross floor area, capped at $7,500,000 per building, with the actual amount scaled by adjustment factors based on how far short of the pathway target the building landed (not simply the maximum figure for any shortfall).

Separately from the Alternative Compliance Payment, DOEE can pursue civil infractions for missing required interim reporting deadlines within a Compliance Cycle -- a building can be on the hook for a reporting-timing violation independent of whether it ultimately meets or misses its performance target.

Step-by-step: how to comply

1. Confirm your building clears the current 10,000 sq ft benchmarking threshold. We check this against your building's details and flag it if you're in the newly-added 10,000-25,000 sq ft band whose first-ever report was only recently due.
2. Set up the property in ENERGY STAR Portfolio Manager with your DC Real Property Unique ID and respond to DOEE's annual data request before May 1. We handle the annual data entry and submission once your utility feed is live -- note that DOEE now layers its BEAM support platform (dc.beam-portal.org) on top of the underlying ESPM submission, so we track both.
3. In 2024, 2027, and every 6 years after that, arrange third-party verification of your benchmarking data. We track this cycle and flag it well ahead of your building's next verification year -- but the verification itself has to come from a real, qualified third-party professional.
4. Separately, confirm whether your building is in BEPS's first compliance population (private buildings over 50,000 sq ft, or any DC-owned building over 10,000 sq ft) and, if so, where it sits against its peer median. We flag your building's likely BEPS exposure based on its size and available performance data -- but choosing and executing a Compliance Pathway is a real capital-planning decision that has to be yours.
5. If your building is tracking toward a Cycle 1 shortfall ahead of the December 31, 2026 cycle-end, evaluate your options -- capital improvements against the Performance Pathway target, a prescriptive path, or budgeting for the Alternative Compliance Payment -- well before the cycle closes, since the ACP scales with how far short you land, not just whether you missed the target at all.

What we handle

DC's benchmarking side is a clean, ESPM-based annual filing for most owners -- the real complexity, and the real financial exposure, is on the BEPS side, where the population is narrower today but the penalty (up to $10/sq ft) is an entirely different scale than benchmarking's $100/day. Run the compliance checker below to confirm your building's current benchmarking threshold status and flag likely BEPS exposure, then join the waitlist. What stays yours: the third-party verification engagement, and the underlying capital or operational decisions behind any BEPS Compliance Pathway.

Frequently asked questions

My building is 15,000 sq ft. Do I have to benchmark it?

Yes, under the current 10,000 sq ft threshold -- and if this is the first year your building has had to report, that's likely a very recent obligation, since DC's threshold only reached 10,000 sq ft with reports first due by May 1, 2026.

Does my 15,000 sq ft building also owe BEPS performance targets?

Not in BEPS's first compliance cycle -- that cycle's private-building population is buildings over 50,000 sq ft. As the benchmarking threshold has ratcheted down, DOEE has signaled that more buildings will be added to BEPS over time, so don't assume a 15,000 sq ft building stays outside BEPS indefinitely, even though it's outside the current cycle's population.

Is DC's benchmarking deadline always May 1?

Yes, as a matter of statute (DC Code § 6-1451.03), with one confirmed exception: 2024 had a one-time July 1 deadline instead of May 1.

Is third-party verification required every 3 years?

No -- that's an outdated framing we've since corrected. The statute specifies 2024, 2027, and every 6 years after that, which is not the same cadence as a flat every-3-years rule.

What's the actual penalty if I just never benchmark?

Up to $100 per day the required submission remains outstanding, with civil infraction sanctions as an alternative route DOEE can pursue. That's a benchmarking-only figure -- it's separate from, and much smaller than, BEPS's up-to-$10-per-sq-ft Alternative Compliance Payment exposure.

How is the BEPS Alternative Compliance Payment actually calculated -- is it always $10/sq ft?

No, $10/sq ft (capped at $7,500,000) is the maximum. The actual payment is scaled by adjustment factors reflecting how far short of the building's Compliance Pathway target it landed -- a building that narrowly missed its target owes meaningfully less than one that missed by a wide margin.

When does BEPS Cycle 1 actually end?

December 31, 2026 -- which, as of this guide's last verification, is only months away. If your building is in Cycle 1's covered population and hasn't evaluated its position against its Compliance Pathway target, that's a near-term priority, not a someday item.