5 things every condo and co-op board must do before December 31.
The December 31, 2026 deadline for DC’s BEPS Cycle 1 is coming faster than most boards realize. Whether your building is close to compliant or well below the target, there are specific actions you need to take now — not in October.
Here’s your no-fluff checklist.
✅ 1 Verify Your Gross Floor Area (GFA) in ENERGY STAR Portfolio Manager
This is the single most overlooked, highest-impact action a condo or co-op can take, and it’s the first thing we check for every new client.
The one thing that surprises most boards: Correcting your building’s Gross Floor Area (GFA) in ENERGY STAR Portfolio Manager can dramatically improve your score — sometimes by 10 to 15 points — without spending a dollar on physical improvements. Most condo and co-op buildings have significantly understated square footage on file because the city pulls from property tax records, which only count unit square footage, not common areas. Fixing it takes about 10 days and is the first thing we check.
Why it matters
DOEE pulls your building’s square footage from property tax records. The problem? Property tax records typically only count individual unit square footage — not hallways, lobbies, mechanical rooms, stairwells, amenity spaces, or any other common areas. That means most condo and co-op buildings have significantly understated square footage in the system.
Why that hurts your score
Both ENERGY STAR Score and Energy Use Intensity (EUI) calculate energy per square foot. If your square footage is too low, your building looks less efficient than it actually is.
What happens when you correct it
- ~95% of condo and co-op buildings we’ve verified have incorrect (understated) square footage on file.
- Corrections have improved Energy Star Scores by as much as 10–15 points.
- Real example: A DC condo went from 47 to 62 after a GFA correction alone — no physical improvements needed.
- It takes about 10 days to complete a GFA verification.
Do this first. It’s the lowest-hanging fruit in BEPS compliance, and it could change your entire situation.
✅ 2 Confirm Your CY2025 Benchmarking Was Submitted
The deadline for submitting Calendar Year 2025 energy data was May 1, 2026. If your building hasn’t submitted yet — get it done now.
Starting this year, DC’s benchmarking requirement now applies to all buildings above 10,000 square feet (down from the previous 25,000 sqft threshold). That means thousands of buildings are newly required to report for the first time.
Penalties for late or missing submissions: $100 per day.
If you’re not sure whether your building is on the DC Covered Building List, check with your benchmarking consultant or reach out to us directly. Don’t assume you’re not covered.
✅ 3 Pull Together Your Energy Improvement Documentation Since 2018
This is essential for the Good Faith Effort (GFE) framework that DOEE is finalizing, and it takes longer to compile than most boards expect.
The GFE pathway is designed to recognize buildings that genuinely tried to improve but couldn’t hit the compliance target — often because of the governance and physical barriers unique to condos and co-ops. To qualify, you’ll need documented evidence of measures taken since January 1, 2018.
Start gathering:
- Energy audits (even preliminary ones count)
- LED lighting upgrades
- HVAC repairs, tune-ups, and replacements
- Variable Frequency Drives (VFDs) installed on pumps or fans
- Smart or programmable thermostats
- Board meeting minutes showing votes on energy-related projects
- Capital improvement projects with an energy efficiency component
- Any studies, reports, or proposals — even ones that weren’t acted on
The more documented evidence you have, the stronger your GFE application. Don’t wait for DOEE to publish the final guidance to start gathering this. It takes time, and the clock is ticking.
✅ 4 Understand Which Compliance Pathway Fits Your Building
Not every building will achieve an Energy Star Score of 66 by December 31. That’s the reality, and DOEE has built pathways to accommodate it. But you need to choose the right one for your specific situation — and then act on it before the deadline.
Quick overview of your options:
- Achieve Compliance: Hit ESS 66 or reduce EUI by 20%. Still achievable for many buildings with targeted projects — especially if GFA verification reveals your score has been artificially suppressed.
- Reinvestment Clause: Penalty dollars get reinvested 100% back into energy improvements at your building. Best for buildings that need more time but have real projects planned.
- Good Faith Effort (GFE): For buildings that tried but faced genuine governance or physical barriers. Five qualifying pathways including a point-based system for completed measures.
- Extended Deep Energy Retrofit (EDER): Long-term compliance pathway requiring 40–50% energy reduction commitment with all-electric upgrades. A serious undertaking, not right for every building.
- Financial Distress Exemption: For buildings with documented financial hardship. Criteria are being updated to reflect condo/co-op realities like reserve balances and special assessment voting thresholds.
Which pathway is right for you depends on your current Energy Star Score, building characteristics, financial situation, and board capacity. This isn’t a decision to make alone — get a professional assessment before the deadline.
✅ 5 Don’t Let December 31 Sneak Up on You
This deserves its own spot on the list because it’s the mistake we see most often.
December 31, 2026 is the hard deadline for submitting:
- Compliance pathway applications (EDER, Reinvestment Clause)
- Good Faith Effort applications
- Financial Distress exemption requests
- Delay requests of any kind
After this date, your options narrow significantly. And here’s the reality: six months sounds like a lot of time. It isn’t — not when you’re coordinating board votes, vendor RFPs, energy audits, and compliance documentation simultaneously. Buildings that start in October consistently run out of runway.
If you haven’t started your compliance planning yet, start now. Today. Not next month.
The bottom line: BEPS compliance isn’t something you resolve in a single board meeting.
It requires a plan, documentation, vendor coordination, and in most cases, professional guidance. The good news: there are real options for condos and co-ops, and DOEE has built in flexibility specifically because of the unique challenges community associations face.
Honeydew Energy Advisors has helped over 1,100 DC buildings navigate benchmarking and BEPS, and not one of our clients has received a penalty. We know the system inside and out, we’re at the table where the rules are being written, and we can help your building find the right path forward before December 31.
Schedule a free BEPS compliance assessment today: honeydewadvisors.com