NYC’s Local Law 97 Is Here in Force. Here’s How to Plan for Compliance.

With the owners of more than 21,000 buildings in New York City due to file their first Local Law 97 (LL97) reports in 2025, there was some uncertainty about whether all would go as planned for those trying to comply with the landmark building performance law.

Would owners be ready on time? How would the reporting process work? Would the law be repealed?

All fair questions given rising insurance costs, tariff uncertainty and other serious challenges faced by the NYC real estate market in recent seasons. But, despite the chaos, the LL97 rollout has seen markedly fewer catastrophes than feared. According to the New York City Department of Buildings (DOB), only a small percentage of owners with reporting due this year have failed to take steps to comply on time. Pretty impressive considering that, up until last year, quite a few owners and managers had no knowledge of the law at all.

Now, as we wrap up reporting for the first year, attention must turn to the future. Most buildings subject to annual emissions reporting will face fines over the next few years, which the Real Estate Board of New York estimates could run to $900 million annually in total, starting in 2030. And, in the longer term, buildings will have to achieve zero emissions by 2050, or pay even larger fines.

Though those numbers sound intimidating, now is the time to plan for short- and long-term compliance. With the right perspective, and the right partner, you can turn performance mandates into opportunities to reduce operating expenditures, achieve corporate sustainability goals and improve property values and tenant comfort.

The original deadline to comply with LL97 was June 30, 2025, but the DOB is offering an extension for year one only. Now, properties must pay filing fees by Aug. 30, and then will have until Dec. 31 to file their reports. 

For properties in need of time beyond the end of 2025, there are other options to consider. For affordable housing or houses of worship completing LL97’s 13 prescriptive measures, the DOB will offer extra time into 2026 to finish installation work via a mediated resolution, if owners apply by the end of this year. For market-rate multifamily and commercial properties subject to annual emissions reporting and fines starting this year, there are numerous types of special considerations. A qualified registered design professional (RDP) can help determine the most appropriate options for your property.

As owners begin preparations for compliance in 2030, most buildings will need to be retrofitted to avoid fines. But a study by the Urban Green Council shows that approximately 60 percent of multifamily buildings won’t need to fully electrify by that point. The majority will be able to comply by implementing lower-cost energy efficiency measures like pipe insulation, radiator controls and lighting upgrades that will reduce some operating costs and improve residential tenant comfort.

For preparations beyond 2030, the first step is a quality energy audit. The path to zero emissions will differ for every property, based on key factors like the remaining useful life of building systems, financing cycles, the availability of incentives and the trajectory of LL97 emissions limits over time. An energy audit can assess these critical questions for owners to consider when mapping out decarbonization projects.

And, when it does come time to electrify, most properties won’t need to immediately electrify the entire property at once. Considering phased, partial or hybrid approaches to electrification can reduce installation costs, and the DOB will even reward certain properties for using a partial approach. Beneficial electrification credits can significantly reduce fines for buildings that install qualifying heat pumps by 2029 and are open to partial electrification projects.

The politics of new and ambitious regulation can often make it seem as if everyone is going bankrupt, but that’s not an accurate representation. There are a small handful of properties with extenuating circumstances that the DOB and the City Council will have to work to accommodate. For the vast majority of owners, however, there are clear and incremental steps to improve the performance of a portfolio over time.

But it takes an expert RDP to ensure that properties are incorporating the latest compliance guidance into planning. With a strong partner, owners and managers can identify strategies to improve efficiency, sustainability and tenant experience without breaking the bank. 

Amanda Clevinger is the policy and programs director at Bright Power, a sustainability and decarbonization consultancy for real estate.