BEPS Compliance Pathway Timelines

Updated: February 2025 to reflect pending legislative changes due to the BEPS Amendment Act of 2024.

A building that does not meet the Standard for its property type at the beginning of the BEPS Period enters into a 5-year Compliance Cycle. The building owner must select a Compliance Pathway and complete the building performance and reporting requirements throughout the Cycle. There are multiple Pathways for a building owner to choose from based on that building’s unique circumstances.

These timelines outline the specific deadlines and reporting requirements associated with each Compliance Pathway to help you understand the implications and major milestones of each Pathway.

The Compliance Pathways

Click on one of the pathways below to view its relevant deadlines and requirements.

Principal Compliance Pathways

• Performance Pathway. The most straightforward Pathway option, it requires a Site EUI reduction of 20%.
• Standard Target Pathway. For specific buildings only, buildings must meet or exceed the Standard for their Property Type.
• Prescriptive Pathway. For people who wish to mitigate risk, this is an action-based approach that requires completing a prescribed approach to energy savings, working in collaboration with DOEE.

Note: the prescriptive pathway is only available for BEPS Cycle 1 per the BEPS Amendment Act of 2024. A new trajectory pathway will be available beginning with the second BEPS compliance cycle on Jan 1, 2028, which allows building owners to establish building-specific performance targets that build towards long-term goal achievement.

Alternative Compliance Pathway Options

• Accelerated Savings Recognition (ASR) Alternative Compliance Pathway (ACP) Option. For building owners who want to achieve long-term compliance through deep energy retrofits during this first Compliance Cycle.
• Extended Deep Energy Retrofits (EDER) Alternative Compliance Pathway (ACP) Option. For building owners who want to achieve deeper energy savings but need more time to do it, as necessitated by certain circumstances.
• New Construction Alternative Compliance Pathway (ACP) Option.  For new buildings issued a Certificate of Occupancy from DCRA (now DOB) before the beginning of the BEPS Period (2019–2020) that did not submit a CY2019 District Benchmark Results and Compliance Report.
• Change of Property Type Alternative Compliance Pathway (ACP) Option. For a building that has entered a Compliance Cycle and then undergoes a renovation that results in a change of property type during the and therefore no longer has an accurate baseline.
• Adjusted Baseline Alternative Compliance Pathway (ACP) Option. For buildings that have had a permanent change, based on certain circumstances, that occurred or are planned to occur during the compliance cycle (from 2021-2026) which may warrant a baseline EUI modification.
• Campus Target Adjustment (CTA) Alternative Compliance Pathway (ACP) Option. For College/University campuses that have Blended Custom Source EUI Standards and undergo major renovation, reconfiguration, addition, or demolition during the Compliance Cycle.
• Custom Alternative Compliance Pathway (ACP) Option. For buildings owners with an interest in implementing an innovative approach to energy efficiency that doesn’t appear to be acceptable under other Compliance Pathways.

The Process

The general process of compliance is the same no matter which Pathway a building owner chooses. Early in the Cycle, an owner is required to select a Pathway. During the Cycle, the building owner implements energy efficiency measures and/or makes operational changes to satisfy the specific energy performance and reporting/verification requirements of the approved Pathway. By the end of the Cycle, the building owner must meet the energy performance requirements and demonstrate successful implementation of the approved Pathway.

DOEE evaluates the building against the Pathway’s requirements to determine if compliance was achieved. If compliance was not achieved, the building will be subject to a penalty and DOEE may pursue enforcement against the building owner.