DC BEPS in 2026: Cycle 1 deadlines and what comes next

DC's Building Energy Performance Standards (BEPS) are close to the end of their first cycle. Cycle 1 runs through December 31, 2026, and the reports that prove where each building landed are due May 3, 2027. If you own or manage a covered building in the District, the next seven months decide how Cycle 1 closes.

Every one of those reports runs on two inputs: the building's floor area and its meter data. Get those right and the rest is paperwork.

What BEPS is

BEPS came out of the CleanEnergy DC Omnibus Amendment Act of 2018. The District's goal is to cut greenhouse gas emissions and energy use 50% by 2032, and BEPS is how existing buildings carry their share.

Each property type has a standard set no lower than the District median ENERGY STAR score for that type (D.C. Code § 8-1772.21). Buildings without an ENERGY STAR score use an equivalent energy use intensity (EUI) metric. A building below its standard has a cycle to close the gap.

DOEE's Guidebook v1.2, published in August 2026, adds a fixed "DC BEPS Score" locked to the ENERGY STAR models in place on January 1, 2021. So if EPA changes its scoring method mid-cycle, your compliance target doesn't move. Hospitals and medical offices feel that most.

Who's covered, and when

• Cycle 1 (2021 to 2026): private buildings of 50,000 sf and up, and District-owned buildings of 10,000 sf and up.
• 25,000 sf and up: from January 1, 2029.
• 10,000 sf and up: from January 1, 2035.

Those last two dates are new. The FY2027 Budget Support Act moved them back a year each (from 2028 and 2034), along with DOEE's deadline to publish Cycle 2 standards, now January 1, 2029. The emergency version took effect August 13, 2026 (D.C. Act 26-416). The codified statute still shows the old dates until the permanent act completes review, so check the current text before you budget around them.

Separately, every private building over 10,000 sf has to benchmark in ENERGY STAR Portfolio Manager by May 1 each year (DOEE).

What changed in 2025

The BEPS Amendment Act of 2024 took effect March 21, 2025. The parts that matter day to day:

• The annual benchmarking deadline moved from April 1 to May 1.
• Third-party data verification moved from every 3 years to every 6: 2024, 2027, then every 6 years after that.
• Cycle 1 became 6 years long. Later cycles run 5 years.
• New whole-cycle exemptions for financial distress and low occupancy.
• Cycle 2 gets a trajectory pathway, which sets interim targets along the way.

One practical consequence: CY2025 data (due May 1, 2026) didn't need third-party verification, but CY2026 data, due May 3, 2027, does.

The Cycle 1 pathways

Each building in Cycle 1 picked a pathway. Here's what each one has to show at the end:

• Performance: a site EUI reduction of more than 20%, comparing CY2026 to the CY2018 to 2019 average (weather and use adjusted).
• Standard Target: reach the property type's standard in CY2026.
• Prescriptive: finish a four-phase process covering the audit, an action plan, implementation, and measurement and verification.
• Alternative Compliance Pathways: options such as Extended Deep Energy Retrofit, Adjusted Baseline, Campus Target Adjustment, and Custom ACP. Under Guidebook v1.2, condos and co-ops can now use Extended Deep Energy Retrofit, and neither it nor Custom ACP can be used to install fuel-burning equipment.

Relief exists too: delays of up to 3 years, an extended delay for qualifying affordable housing, and the new exemptions.

The dates to put on the calendar

May 3 is a Monday because May 1, 2027 falls on a Saturday. Source: Guidebook v1.2 and the Building Innovation Hub.

A building that misses its pathway owes an alternative compliance payment of up to $10 per square foot of gross floor area, capped at $7.5 million, reduced in proportion to how close it got to its target (Guidebook §7.1). The payment scales with the result, and the result depends on two numbers.

Where the numbers come from

Both the Performance and Standard Target results are math on two inputs: energy, and gross floor area. EUI is energy divided by floor area. The ENERGY STAR score is built on the same denominator.

So an error in either one moves your result directly. We've seen a Portfolio Manager record with a use entered twice, which roughly halved the building's reported EUI. We've seen garage area left inside a gross floor area that should have excluded it. Neither shows up until somebody checks the record against the drawings and the bills.

Before May 2027, I'd do three things:

1. Check the floor area in Portfolio Manager against the building's drawings or assessor records, with parking classified the way ENERGY STAR defines it.
2. Check every meter against the utility bills for CY2026, and close any gaps before the year ends.
3. Line up the third-party verification early. CY2026 is a verification year, and verifiers get busy in spring.

DOEE's resources are now on the BEAM portal, and the Building Innovation Hub keeps a vendor directory and a sample verification scope of work.

How we help

ThresholdStack measures gross floor area from the source, reconciles it against Portfolio Manager, and verifies benchmarking data with a licensed Professional Engineer signing the checklist. Every figure and document lands in the building's BuiltLedger record, so the May 2027 filing starts from data that's already been checked.

See how we measure floor area and verify benchmarks

Updated October 2026. BEPS rules are changing through 2026 and 2027; check DOEE's current guidance before you file.