A building may not have to meet stricter energy performance or emissions reduction targets for several years. But an HVAC replacement, controls upgrade, renovation, or capital budget approved today could determine how difficult that future requirement will be to meet.

Building Performance Standards (BPS) set energy-use or greenhouse gas emissions targets for existing buildings. Requirements and deadlines vary by jurisdiction, but the challenge for owners is the same: The compliance deadline is not necessarily the planning deadline. Waiting too long can leave owners with fewer options and less time to align improvements with planned equipment replacements and budgets.

Sixteen U.S. jurisdictions have adopted building performance standards, with six reaching a first reporting or evaluation year in 2025 or 2026. Requirements vary by jurisdiction and continue to evolve. Owners do not need to predict every change, but they do need to understand how their buildings perform now, when that performance will be measured, and which investments made today could reduce future compliance exposure.

Is Energy Benchmarking Enough for Building Performance Standards?

The short answer is no. Energy benchmarking shows how a building is performing, but it does not itself address performance standards, especially if there is a gap. Benchmarking is an important part of preparing for building performance standards because it allows owners to track how that performance changes over time. ENERGY STAR benchmarking through Portfolio Manager is a great place for building owners to start. Nearly 25% of U.S. commercial building floor space is actively benchmarked through the platform.

Benchmarking provides the information owners need to make informed decisions. Some jurisdictions require only benchmarking, which establishes a consistent record of a building’s energy use or emissions and shows how performance changes over time. Other jurisdictions go further by setting a building performance standard that requires owners to address the gap between current performance and a defined target. The distinction is important: benchmarking identifies where a building stands, while a performance standard establishes where it must go. Together, that information helps owners determine which properties face the greatest exposure and where operational improvements or capital investments may be needed.

The Compliance Deadline Is Not Your Planning Deadline

Once owners understand where a building stands relative to current and future performance requirements, the next question is how much time they have to respond. A compliance deadline may still be years away, but major building systems and capital plans operate on different timelines. Identifying a potential performance gap early gives owners more flexibility to address it through planned equipment replacement, renovations, and normal budgeting cycles.

New York City's Local Law 97 illustrates the difference between current compliance and future readiness. 2023 data showed an estimated 92% of covered buildings already met the law's 2024 emissions limits. However, as of 2024, only 43% met the stricter limits that take effect in 2030. That means many owners can be compliant today while still having a meaningful performance gap to address over the next several years.

That gap is where planning time matters. If a central plant, rooftop unit, controls system, or other major asset is likely to be replaced before a future performance requirement takes effect, that project can become an opportunity to address the building's longer-term needs. Waiting until the next threshold is close can narrow those options.

For a Portfolio, Start with the Buildings That Have the Most Exposure

For a single building, planning for future performance requirements means deciding which improvements matter most, when they should happen, and how they fit within available capital. Owners may need to weigh lower-cost operational changes against larger equipment replacements or other capital projects.

For a portfolio, there is another layer of prioritization. Owners also need to determine which buildings deserve attention first. Benchmarking data helps identify properties with higher energy use or a larger performance gap, but it should not be the only factor. Equipment age, known operating issues, planned renovations, replacement cycles, and future BPS requirements can all affect where you direct time and capital.

That makes the first question less about "What should we upgrade?" and more about "Where should we focus first?"

One building may have high energy use and an HVAC system nearing replacement. Another may have newer equipment but operational problems that can be addressed sooner and at lower cost. A third may already be well positioned against future requirements.

The goal is not to push every property into immediate capital work. It is to identify where performance risk and upcoming investment decisions overlap, then prioritize the buildings and improvements where early action can deliver the most value.

More Time Lets Owners Choose the Right Level of Intervention

Long-term building performance standards can often feel like massive hurdles. Take another look at New York’s Local Law 97, which sets increasingly stringent emissions limits for covered buildings as part of the city’s goal to reduce emissions from its largest buildings by 40% by 2030 and reach net zero by 2050. At first glance, targets like these can suggest that existing buildings will require major overhauls. In practice, the right response depends on the building and what is driving its performance gap.

For some buildings, the first step may simply be understanding where the opportunities are. An energy audit can identify how energy is being used, where inefficiencies are occurring, and which improvements are worth evaluating further. If the equipment itself is adequate but controls, schedules, sensors, setpoints, or system interactions are limiting performance, retro-commissioning can help identify and correct those issues before owners move toward unnecessary equipment replacement.

When major systems are already approaching replacement or a renovation is planned, energy modeling and engineering analysis can help compare alternatives and understand how different decisions could affect future energy use or emissions.

The key is matching the response to the building. Identifying the performance gap early gives owners more time to pursue the improvements that make sense, rather than assuming that meeting a future standard requires one large capital project.

Turn Performance Data into a Plan

Preparing for building performance standards does not stop with benchmarking or end with a single capital project. The first step is knowing how each building is performing today and which ones may need attention sooner.

Emerald Built Environments, A Crete United Company, helps owners prepare for current and future BPS requirements through benchmarking, energy audits, retro-commissioning, energy modeling, engineering, and capital planning. Starting earlier gives owners more time to evaluate their options and make decisions on their own timeline, rather than when a compliance deadline is approaching.