Energy benchmarking and ordinance filing used to feel straightforward: benchmark annually, submit once, move on. That is not the world we are in anymore. In our energy benchmarking webinar, we break down what compliance looks like in 2026 and how real estate teams should prepare.
In the session, Brendon Donoghue, Director of Sustainability Services at Measurabl, and Mike Zatz, Senior Sustainability Services Manager, walked through what is changing for 2026, where portfolios are most exposed, and how real estate teams can reduce risk before filing deadlines cluster this spring. Drawing on thousands of buildings across North America, they shared practical insights from teams navigating expanding ordinances, performance standards, and verification requirements.
This webinar focused on what is changing for 2026 and what teams can do now to reduce risk, avoid last-minute scrambles, and build a repeatable process that scales as requirements grow.
Watch the full webinar here:
Why Energy Benchmarking Compliance Is More Complex in 2026
- Ordinance filing is getting harder because the rules are fragmenting, not because teams are doing anything wrong
A core point came through clearly: missed deadlines and incomplete filings are rarely the result of apathy. They are usually the result of complexity.
Most portfolios are exposed to at least one ordinance, and many are exposed to multiple. Each jurisdiction can come with different thresholds, different deadlines, different reporting requirements, different submission mechanics, and sometimes entirely different portals. Even when the starting point is the same tool (ENERGY STAR Portfolio Manager), the process after that diverges.
In the energy benchmarking webinar we share one practical takeaway: treat compliance as a program, not a task. If your approach is “we handle it when the due date comes,” you are setting yourself up for reactive work and avoidable risk.
- Data Quality and Audit Readiness in Energy Benchmarking
One of the biggest shifts is the growing expectation that reported data needs to be accurate, auditable, and in some jurisdictions, verified.
Cities and states are using benchmarking data not just for transparency, but for policy, enforcement, and performance standards. When the data is messy, incomplete, or inconsistent, it creates risk. Not just reputational risk, but operational risk in the form of failed submissions, rework, and potential penalties.
If you do one thing differently this year, make it this: build in time for QA. Filing early is not just about being “done.” It creates runway to validate the data and resolve issues before you are up against the deadline.
- Building Performance Standards and Compliance Risk
Even though this webinar focused on energy benchmarking and ordinance filing, the broader context matters: more jurisdictions are moving from “report it” to “meet a standard.”
Building Performance Standards (BPS) introduce caps on energy use or emissions. In markets where BPS is active or emerging, teams may face additional reporting steps and separate submission requirements outside Portfolio Manager.
That means compliance work is no longer contained in one place. It is becoming multi-system and multi-stakeholder, especially for portfolios operating in major metro areas.
- The teams that win compliance season start now, not in April
Most deadlines still cluster in spring (often April through June), with some notable exceptions. But the best time to build your plan is before filing season starts.
The most common failure mode is predictable: you realize you are exposed, you realize utility data is missing or hard to obtain, and you are suddenly trying to fix data quality issues days before submission.
A strong compliance season is not about heroics. It is about sequencing:
- confirm exposure
- confirm data readiness
- confirm ownership
- execute early enough to catch issues
That is the difference between “we got it done” and “we can do this every year without panic.”
2026 Ordinance Filing Updates Real Estate Teams Should Know
This session highlighted several 2026 changes that reflect the direction the market is moving: more programs, broader coverage, and more scrutiny.
New ordinances and expanding metro coverage
A clear trend stated in the energy benchmarking webinar is that ordinances are spreading beyond major cities into adjacent municipalities. Programs are showing up in places that previously felt “outside the compliance footprint,” which can catch portfolios off guard if they are only tracking the obvious top markets.
Several new or emerging programs were called out, including New Orleans and jurisdictions around Los Angeles (West Hollywood and Santa Monica). The specific markets are less important than the signal: expansion is continuing, and it is often happening right outside cities that already have long-standing requirements.
Washington, D.C.: expanded coverage
Washington, D.C. is expanding coverage to buildings 10,000 square feet and above in 2026. This is a meaningful shift because it brings more mid-size buildings into scope and increases portfolio exposure for teams that assumed only their largest assets required compliance.
Boston BERDO: verification is here
Boston’s BERDO program is adding a data verification requirement in 2026 (on a recurring cycle). This is part of a larger pattern: jurisdictions want to trust the data they are receiving.
Boston is also a reminder that compliance is no longer one-dimensional. Benchmarking and performance standards are increasingly intertwined, so teams need to think beyond “did we submit” and toward “is our reporting defensible.”
New York City: performance standards are real and active
New York City’s Local Law 97 is one of the most visible examples of how quickly BPS can change expectations. The point for the webinar audience was not to re-litigate LL97 details, but to emphasize that performance standards and enforcement are no longer theoretical.
If you have assets in markets where performance standards exist or are coming soon, the value of clean benchmarking data goes up dramatically. Benchmarking becomes the foundation for decision-making, not just a compliance requirement.
Maryland: statewide programs add another layer
State-level requirements can create a new kind of complexity: local rules plus state rules, sometimes with different thresholds and timelines.
Maryland was mentioned as an example of a statewide program that teams should make sure they have correctly tracked. The best takeaway here is operational: do not assume local compliance automatically covers state compliance unless the program explicitly says so.
What “good” looks like for compliance season
The most useful part of the webinar was a simple framework for running a clean season, regardless of portfolio size.
Step 1: Know your exposure across the portfolio
This is the starting point because everything else depends on it. You cannot plan resourcing, request utility data, or schedule verification if you are not certain which buildings are covered, by which programs, and on what timeline.
Exposure is also not static. New ordinances are introduced. Thresholds change. Requirements expand. A plan built on last year’s list can easily be wrong this year.
Step 2: Make your data audit-ready
Ask a blunt question: if a jurisdiction audited your submission, would you be confident in the trail? Audit-ready does not mean perfect. It means:
- the right meters and utilities are accounted for
- the data covers the correct reporting year
- building attributes are accurate (size, use type)
- outliers have been reviewed
- you can explain why the data looks the way it does
This is where many teams get stuck because the work spans multiple stakeholders (property management, utilities, third-party billing, engineers). It takes time, and it is almost impossible to do well under deadline pressure.
Step 3: Establish clear ownership and a repeatable workflow
Compliance falls apart when responsibility is vague. Someone needs to own:
- ordinance tracking
- Portfolio Manager setup and sharing
- data completeness and QA
- submission mechanics and portal work
- documentation and record-keeping
Even if multiple people execute pieces, clarity on ownership reduces delays, missed handoffs, and late-stage fire drills.
Step 4: Execute early enough to avoid “deadline chasing”
A recurring message was that the biggest risk is not the ordinance itself. It is a scramble.
When teams are forced into reactive work, they make compromises:
- submitting without QA
- accepting gaps in data
- missing a step in a portal
- forgetting a sharing requirement
- misunderstanding which program applies
Early execution is how you buy time to prevent those errors.
Does ENERGY STAR Portfolio Manager Equal Energy Benchmarking Compliance?
Many real estate teams assume that entering data into ENERGY STAR Portfolio Manager automatically means they are compliant with local energy benchmarking laws. It does not
Benchmarking in ENERGY STAR Portfolio Manager is usually required, but simply entering the data does not automatically mean you filed correctly. Many programs require you to take a specific action to share or submit the data to the jurisdiction.
Common submission models include:
- Sharing access in Portfolio Manager (adding a jurisdiction as a contact and sharing building data)
- Submitting a generated report in Portfolio Manager
- Using an external portal (more common when performance standards are involved)
The operational implication: compliance requires a workflow, not a dataset.
If your process is “our data is in Portfolio Manager so we should be fine,” this is a good year to pressure-test that assumption.
Two practical pathways: DIY compliance vs supported ordinance filing
There is no one “right” approach, but the webinar made the tradeoffs clear.
DIY energy benchmarking filing: high control, high operational burden
Managing ordinance filing internally can absolutely work. Many organizations do it successfully. But it works best under specific conditions.
In our energy benchmarking webinar we walk through how DIY tends to be effective when you have:
Dedicated internal ownership
Not “someone who helps with it,” but someone accountable for ordinance tracking, submission mechanics, and deadline management.
Strong familiarity with each program you are exposed to
That includes thresholds, reporting nuances, submission methods, and verification requirements. And that knowledge has to be refreshed every year.
Time to coordinate utilities and stakeholders
Utility data rarely flows perfectly. Someone has to chase down missing meters, resolve data gaps, confirm square footage, and validate anomalies.
Capacity to manage multiple portals and evolving rules
Even when Portfolio Manager is the foundation, many jurisdictions require sharing actions, generated reports, or entirely separate portals for submission, especially where performance standards are involved.
DIY gives you full visibility and control. But the operational burden increases as:
- Your portfolio spans more jurisdictions
- Thresholds drop and more buildings come into scope
- Verification requirements become more common
- Programs introduce new portals or updated submission mechanics
The more fragmented the landscape becomes, the more DIY starts to feel like project management layered on top of sustainability work. For lean teams, the risk is not capability. It is bandwidth.
Supported energy benchmarking ordinance filing: lower lift, more consistency
End-to-end support reframes ordinance filing from a seasonal task into a managed function. Instead of asking, “Did we submit?” the focus shifts to more important questions:
- Do we know exactly where we’re exposed?
- Is our data defensible?
- Is execution consistent across markets?
- Are we more efficient this year than last?
End-to-end support isn’t about outsourcing responsibility. It’s about building compliance infrastructure. Infrastructure means you’re not rediscovering exposure each year. You have a clear, centralized view across your portfolio. Deadlines are sequenced intentionally, not reacted to. Data is reviewed and documented before submission, not scrambled together at the last minute.
Execution becomes standardized. ENERGY STAR sharing, jurisdiction-specific submission steps, and external portals are handled through a defined process instead of institutional memory. When programs update or new ordinances pass, they’re absorbed into an existing framework rather than creating disruption.
Compliance stops consuming your Q2. Portfolio growth doesn’t automatically mean more internal burden. And your sustainability team can focus on performance strategy, capital planning, and preparing for performance standards instead of chasing utility data and portal logins.
That’s the difference between filing reports and operationalizing compliance.
2026 Energy Benchmarking Readiness Checklist
If you want a fast self-assessment, these questions do most of the work:
- Do we know which buildings are exposed to which ordinances?
- Is our data complete, accurate, and defensible?
- Is ownership clear, and do we have a workflow that does not depend on heroics?
If any of those answers is “not fully,” you likely have process risk hiding in plain sight. Our Ordinance Filing Readiness Checklist breaks this down into a practical, step-by-step assessment you can use internally with your team.
Download it here and see where you stand before filing season accelerates.
Need support for 2026 ordinance filing?
Whether you are managing a handful of buildings or a multi-market portfolio, our Sustainability Services team provides end-to-end ordinance support across North America, including:
- Exposure mapping and ordinance tracking
- Portfolio Manager setup and QA
- Data validation and documentation
- Jurisdiction-specific submission handling
- Verification coordination where required
If you want to reduce lift this season and build a repeatable compliance process, talk to our team about ordinance support.
Get ordinance filing support here.
Energy Benchmarking Webinar FAQs
What is an energy benchmarking webinar?
An energy benchmarking webinar explains compliance requirements, reporting steps, and regulatory updates for buildings subject to benchmarking laws.
Does entering data in ENERGY STAR Portfolio Manager mean you are compliant?
No. Most jurisdictions require sharing, submission actions, or additional portals beyond simply entering data.
What changed in energy benchmarking requirements for 2026?
Expanded coverage in several jurisdictions, new verification requirements, and growing integration with building performance standards.
Big thank you to our speakers, Brendon and Mike!
