DC Energy Performance Standards (BEPS) and the Start of Fines This Month

If you own or manage a commercial building in Washington, D.C., a local energy regulation could significantly affect your operations: Building Energy Performance Standards (BEPS). As of November 2025, fines will begin for buildings that fail to meet compliance benchmarks. And if you own property in Maryland, a similar policy is on the way.

At Lightility, we help building owners, property managers, and energy professionals respond to BEPS with smart energy strategies. This guide outlines what BEPS means, who’s affected, and how to move forward with compliance.

What Is BEPS?

BEPS is a building energy efficiency policy adopted by the District of Columbia. It requires buildings to meet minimum energy performance thresholds based on ENERGY STAR® scores or Site Energy Use Intensity (EUI). Properties that use significantly more energy than average must improve their performance, or face penalties.

BEPS is one of the District’s key policies supporting its goal to reduce greenhouse gas emissions by 50% by 2032 and move toward carbon neutrality by 2050.

Unlike earlier energy disclosure policies, BEPS is not just about reporting. It’s about taking action.

Who Needs to Comply?

In Washington, D.C., compliance is already active and applies in cycles. Here’s how it breaks down:

• Cycle 1 (Current): All private buildings over 50,000 square feet
• Cycle 2 (Starting 2028): Applies to buildings over 25,000 square feet
• Cycle 3 (Starting 2034): Will include buildings over 10,000 square feet

Cycle 1 began in 2021. The compliance period runs from 2021 to 2026, and fines for noncompliance are now being enforced.

What Happens If You Don’t Comply?

If a covered building fails to meet its selected compliance pathway under D.C.’s BEPS, it may face a penalty of up to $10 per square foot of gross floor area, subject to a maximum penalty of $7,500,000 per property. This is no longer hypothetical. The District Department of Energy and Environment (DOEE) is actively enforcing Cycle 1 and has the authority to assess penalties.

Why You Should Act Now

BEPS is about more than avoiding fines. Delaying compliance can affect financial performance, property value, and future leasing potential. Acting now gives you:

• More time to analyze energy usage and select the right pathway
• Access to local and federal incentives that help cover upgrade costs
• Greater flexibility in selecting and completing upgrades
• Opportunities to align with ESG goals and reporting frameworks

Lightility works with clients to prioritize projects with long-term impact, like LED retrofits, solar integration, and load balancing.

A Quick Look at Maryland’s BEPS

While D.C. is enforcing BEPS now, Maryland’s version of the policy is just around the corner. Under the Climate Solutions Now Act of 2022, commercial and multifamily buildings across the state will also be required to reduce emissions and report performance.

Key Milestones:

• 2025: Buildings over 35,000 square feet must begin annual energy benchmarking
• 2026: Compliance requirements begin phasing in, with final rules expected in 2025.
• 2030: Buildings must show progress toward emissions‑reduction targets once finalized.
• 2040: Buildings must achieve net-zero emissions

Maryland’s Department of the Environment (MDE) has already published initial guidance and is finalizing rulemaking in 2025.

If your building exceeds the emissions cap, you may face fines based on each metric ton of CO2, increasing over time.

What You Should Do Next

If you own or operate a large building in D.C. or Maryland, here’s how to get ahead:

1. Confirm If Your Building Is Covered

Start by checking your building size and type to see whether it falls under the BEPS requirements in either jurisdiction.

2. Begin Benchmarking

Use tools to track current performance. Lightility helps clients set up and manage benchmarking accounts for both local and national compliance programs.

3. Explore Compliance Pathways

D.C. offers multiple compliance routes, including:

• Standard Compliance: Meet the BEPS threshold outright
• Performance Pathway: Achieve a 20% reduction in site EUI
• Prescriptive Pathway: Complete approved building upgrades
• Alternative Compliance Pathway: For special cases like historic buildings or financial hardship

Each has distinct reporting and performance milestones.

4. Identify the Right Upgrades

Many clients see strong returns on:

• Lighting retrofits and controls
• HVAC system upgrades
• Solar installations
• Smart meters and building automation systems

Lightility can model energy and cost savings for each option to help you prioritize.

5. Develop a Compliance Plan

Your plan should account for timelines, budgets, construction disruptions, and tenant coordination. We help build realistic implementation schedules that align with BEPS cycles and your operating goals.

How Lightility Helps

We provide end-to-end support to building owners and facility managers navigating BEPS compliance:

Energy Benchmarking and Diagnostics

We pull your utility data and complete ENERGY STAR Portfolio Manager setup. From there, we assess how your building compares to performance standards.

Upgrade Strategy and Modeling

We analyze which upgrades will have the most impact and fit your budget. That includes capital planning tools and custom financial modeling.

Project Execution

We deliver turnkey lighting, EV charging, and solar installations with complete permitting, design, and construction.

Incentive Identification

Our team stays current on available grants, tax credits, and rebate programs so you can offset costs.

Performance Tracking and Reporting

We monitor energy use after upgrades and help you stay on track for current and future compliance requirements.

BEPS Isn’t Going Away

BEPS is now an operational and financial reality. Washington, D.C. is enforcing the first cycle, and Maryland will soon follow. Whether your goal is to avoid fines, attract tenants, or meet ESG goals, energy performance upgrades can play a central role.

With the right plan and support, compliance becomes an opportunity, not just a regulation to navigate.

Let’s Talk About Your Building

Have questions about how BEPS affects your property? Want to explore what upgrades could bring your building into compliance?

Lightility is already working with owners across D.C., Maryland, and beyond to turn complex policies into smart energy decisions. Contact us today to get started.

Frequently Asked Questions

What is BEPS?

BEPS stands for Building Energy Performance Standards. It sets minimum energy performance targets for buildings in places like Washington, D.C. and Maryland.

When do BEPS fines start in D.C.?

Fines for noncompliance in D.C. begin in November 2025 for buildings over 50,000 square feet.

Who is required to comply with BEPS in D.C.?

Currently, private buildings over 50,000 square feet must comply. Buildings over 25,000 square feet will be included starting in 2028.

What happens if my building doesn’t meet BEPS requirements?

You may face fines as high as $10 per square foot, depending on your compliance path and building size.

Is Maryland enforcing its own version of BEPS?

Yes. Benchmarking for buildings over 35,000 sq. ft. begins in 2025. Enforcement of performance standards will follow, but exact penalties and timelines are still being finalized.

How can Lightility help with BEPS compliance?

Lightility helps you benchmark your building, plan upgrades, manage installations, and apply for incentives.

What kinds of upgrades help meet BEPS goals?

Common upgrades include LED lighting, solar panels, EV charging stations, and building automation systems.

Can I choose how I comply with BEPS?

Yes. D.C. and Maryland both offer multiple compliance pathways, including performance improvements or specific upgrades.

Is BEPS compliance required for multifamily buildings?

Yes. In both D.C. and Maryland, large multifamily properties are included if they meet the square footage threshold.