What is Local Law 97?
Local Law 97, part of NYC's Climate Mobilization Act and codified at Administrative Code section 28-320, sets annual greenhouse gas emissions limits for buildings over 25,000 square feet. The NYC Department of Buildings (DOB) administers it through its rule, 1 RCNY 103-14.
Each covered building files an emissions report every year. Buildings that exceed their limit face a penalty of $268 per metric ton of CO2e over the limit. For a building that exceeds its limit by 500 metric tons, that is $134,000 for the year.
The first annual report, covering calendar year 2024, was due May 1, 2025. The report covering 2025 was due May 1, 2026. If your building has not filed it, a monthly failure-to-file penalty applies, and there are concrete steps to limit it (see the section on unfiled reports below).
Where Things Stand in Late 2026
- Annual reports, due May 1: the report for 2024 was due May 1, 2025, and the report for 2025 was due May 1, 2026. The report for 2026 is due May 1, 2027.
- 60-day grace period: the failure-to-file penalty applies only if the report is not filed within 60 days after May 1 (or after an approved extension). For the 2026 deadline, that grace period has ended.
- Failure-to-file penalty: gross floor area multiplied by $0.50 for each month the report is not submitted, within the 12 months following May 1.
- Good faith efforts: these are a mitigating factor that may reduce a penalty. They are not a separate filing deadline (details below).
Emissions Limits by Period
LL97 sets emissions limits that become stricter over time. Each building's limit depends on its occupancy and floor area.
2024 to 2029 Limits (Current)
Annual reports and penalties now apply.
The first report, for 2024, was due May 1, 2025. Each year's report is due May 1 of the following year.
Next report: May 1, 2027 (for 2026)
2030 and Later Limits
Stricter limits.
Limits tighten starting in 2030. Owners relying on a decarbonization plan to show good faith efforts must have an approved application for the work needed to meet the 2030 limit by May 1, 2028.
Plan ahead: large retrofits take time to design, permit and build
LL97 Penalties: The Financial Reality
There are two main LL97 penalties, both set out in 1 RCNY 103-14:
Emissions Over the Limit
$268 per metric ton over limit
The penalty is the building's actual emissions minus its limit, multiplied by $268 per metric ton of CO2e (103-14(h)).
Example: 500 metric tons over the limit × $268/metric ton = $134,000 for that year
The penalty applies for each year the building's reported emissions exceed its limit. A building 500 tons over its limit for five years would face $670,000 in total.
Failure to File the Annual Report
$0.50 per sq ft per month
If the report is not filed within 60 days after May 1 (or after an approved extension), the penalty is the building's gross floor area multiplied by $0.50 for each month the report is not submitted, within the 12 months following May 1 (103-14(g)). An extension can be requested no earlier than 30 days before and no later than 60 days after May 1.
Example: 100,000 sq ft × $0.50 = $50,000 for each month the report is not submitted
| Non-Compliance Scenario |
Penalty |
Over 5 Years |
| Report not filed (100,000 sq ft building) |
$0.50 per sq ft per month = $50,000 for each month not submitted, within the 12 months following May 1 |
Applies separately to each year's report |
| 350 metric tons over the limit |
$93,800 per year |
$469,000 |
| 600 metric tons over the limit |
$160,800 per year |
$804,000 |
| 1,000 metric tons over the limit |
$268,000 per year |
$1.34M |
Good Faith Efforts: How a Penalty May Be Mitigated
There is no "Good Faith Effort deadline" that owners must meet each year. Under 1 RCNY 103-14(i)(2), good faith efforts are a mitigating factor that may reduce a penalty.
What every owner must do to qualify
- File the annual LL97 emissions report
- Benchmark the building (LL84)
- Attest to the LL88 lighting and sub-meter upgrades
And show at least one of the following
- A decarbonization plan certified by a registered design professional and submitted no later than May 1, 2025, with follow-on milestones: work to meet the 2024 limit done within 24 months of the plan, and an approved application for the work to meet the 2030 limit by May 1, 2028
- An approved DOB application (or a signed contract) for the work needed to meet the 2024 to 2029 limit
- Electric-readiness work
- A prior report showing the building under its limit in 2024 to 2029
- A showing of impact on a critical facility
- An adjustment application
Mediated Resolution
Under 1 RCNY 103-14(j)(3), DOB may offer a mediated resolution to owners who have filed their report and shown good faith efforts.
- Filing the annual report is the starting point for any mitigation
- Mitigation reduces a penalty at DOB's discretion; it is not automatic
- The decarbonization plan route required a plan submitted by May 1, 2025; owners who missed it should look at the other qualifying showings above
Report Not Filed for 2025? Do This Now
The report for 2025 was due May 1, 2026, and the 60-day grace period has ended. The failure-to-file penalty is charged for each month the report is not submitted, so every month of delay has a fixed, avoidable cost:
- File now, even late. For a 100,000 sq ft building, each month the report remains unfiled adds $50,000.
- Assess your mitigation eligibility. Good faith efforts require a filed report, LL84 benchmarking and the LL88 attestation, plus one of the qualifying showings listed above. Assemble the documents before engaging DOB.
- Quantify your exposure before DOB does. Calculate your actual emissions against your limit so you work from your own numbers.
- Plan the work. An approved DOB application or a signed contract for the work needed to meet the limit is itself one of the qualifying showings.
Key Compliance Deadlines
-
May 1, 2025
First annual LL97 report due (for 2024). Last day to submit a decarbonization plan for the good faith efforts plan route.
-
May 1, 2026
Annual LL97 report due (for 2025). The failure-to-file penalty applied if it was not filed within 60 days.
-
May 1, 2027
Annual LL97 report due (for 2026). Extension requests are accepted from 30 days before to 60 days after this date.
-
May 1, 2028
For owners on the decarbonization plan route: approved application for the work needed to meet the 2030 limit.
-
2030
Stricter emissions limits take effect.
How Insparisk Helps You Achieve Compliance
Insparisk provides end-to-end LL97 compliance support:
1
Energy Audit (LL87)
We conduct a comprehensive energy audit to identify your building's current performance, efficiency opportunities, and emissions baseline. This directly informs your LL97 compliance strategy.
2
Emissions Analysis & Gap Assessment
We calculate your building's current emissions against its 2024 to 2029 limit, identify the gap, and look ahead to the 2030 limit. We model different retrofit scenarios and ROI.
3
Compliance Plan Development
For buildings needing time or phased retrofits, we develop detailed decarbonization plans with timelines and budgets, and help you document good faith efforts.
4
Retrofit Project Management
We coordinate HVAC, boiler, lighting, insulation, and renewable energy projects to maximize efficiency gains and stay on schedule for compliance milestones.
5
Annual LL97 Reporting & Compliance Filing
We gather energy data, calculate emissions, and file your annual LL97 report with DOB by May 1, so your building avoids the failure-to-file penalty.
Frequently Asked Questions
Does Local Law 97 apply to my building?
LL97 applies to buildings over 25,000 square feet. This includes residential apartments, office towers, hotels, retail, warehouses, and mixed-use buildings. Condos and co-ops are covered too; how the obligations are handled can depend on how the building is metered. Contact Insparisk for a free assessment of your building's LL97 obligations.
Is there a Good Faith Effort deadline?
No. Under 1 RCNY 103-14(i)(2), good faith efforts are a mitigating factor that may reduce a penalty. To qualify, an owner must file the annual report, benchmark, and attest to the LL88 lighting and sub-meter upgrades, and show at least one of: a decarbonization plan submitted no later than May 1, 2025; an approved DOB application or signed contract for the work to meet the 2024 to 2029 limit; electric-readiness work; a prior report under the limit; a critical facility impact; or an adjustment application. DOB may also offer a mediated resolution to owners who filed and showed good faith efforts.
How are LL97 penalties calculated?
Exceeding the limit: actual emissions minus the limit, multiplied by $268 per metric ton of CO2e. A building 500 metric tons over its limit owes 500 × $268 = $134,000 for that year. Failing to file: if the annual report (due May 1) is not filed within 60 days, the penalty is gross floor area × $0.50 for each month the report is not submitted, within the 12 months following May 1. For a 100,000 sq ft building, that is $50,000 per month.
What are the most cost-effective compliance strategies?
The best strategy depends on your building's current energy profile. Common measures include: (1) LED lighting, (2) HVAC optimization and controls, (3) boiler replacement or conversion, (4) Building Automation System (BAS) upgrades, (5) insulation improvements, (6) solar photovoltaic systems, and (7) heat pump conversion for space and water heating. A professional energy audit identifies your building's specific opportunities and provides payback calculations.
What is the difference between LL97 and LL87?
LL87 is an energy audit and retro-commissioning requirement for buildings over 50,000 square feet, due December 31 of the year whose last digit matches the last digit of the building's tax block number. It tells you where your building stands: current energy use, efficiency opportunities, and payback periods. LL97 is the emissions limit and penalty law. It tells you where you need to be. Together, LL87 provides the roadmap and LL97 provides the limits and penalties.
For a deeper look at exactly how the penalty is calculated, including per-ton math, the failure-to-file penalty, and how good faith efforts can mitigate a penalty, see our detailed article: How NYC's LL97 Carbon Penalty Actually Works.
Find Out if Your Building Exceeds LL97 Limits
The next annual report is due May 1, 2027. Start your compliance assessment now and avoid penalties.