DC’s BEPS Evaluation Year Is Here | Honeydew Energy Advisors

If you’re a condo or co-op board, here’s what you need to know.

2026 is the year DC’s Building Energy Performance Standards (BEPS) goes from something you heard about at a board meeting to something that actually affects your building. This is the “evaluation year,” meaning DOEE is now formally assessing whether your building met its Cycle 1 target.

Here’s the honest truth: most DC condos and co-ops won’t be in full compliance. And that’s okay, for now. You still have time to act. But you need to understand what’s happening and what your options are.

What Is BEPS, and Why Does 2026 Matter?

BEPS stands for Building Energy Performance Standards. It’s DC’s law requiring buildings above 10,000 square feet to actually reduce their energy use, not just report it.

Benchmarking = reporting your building’s energy use every year to DOEE via ENERGY STAR Portfolio Manager.
BEPS = making actual changes so your building gets more efficient. It requires real improvements, not just data submission.

The Cycle 1 standard: Your building needs to reach an “ENERGY STAR Score” of 66 or higher, OR reduce its Energy Use Intensity (EUI) by at least 20% from its 2019 baseline.

2026 is the first year DOEE officially evaluates your building’s Cycle 1 compliance. Think of it as the moment grading begins, but the test isn’t over yet. You still have until December 31, 2026 to submit exemption requests, pathway applications, and delay filings. After that date, your options change materially.

What “Non-Compliance” Actually Looks Like

Non-compliance doesn’t mean a fine letter shows up on your doorstep tomorrow. Here’s how the process actually works:

DOEE reviews your 2025 benchmarking data (due May 1, 2026).
They assess your building’s compliance status against the standard.
If you’re below the target, you’re subject to penalties — up to $10 per square foot, per year.
But you have until December 31, 2026 to request a compliance pathway, exemption, or delay.

A building at an Energy Star Score of 56 that does nothing is in a very different position than a building at 56 that has filed for a pathway. Taking action — and documenting it — is what matters.

The Unique Challenge for Condos and Co-ops

Condos and co-ops face obstacles that commercial buildings simply don’t:

Governance barriers: Unit owners — not the association — control in-unit HVAC and appliances. The board can’t force upgrades without risking legal challenges.
Financial constraints: Special assessments to fund large energy projects often require a supermajority vote (67–75% of owners). That’s not easy to achieve.
Physical barriers: Individual unit metering, submetering gaps, and historic designations all create complications that commercial buildings don’t deal with.

This is exactly why DC created the Condo/Co-op Subcommittee of the BEPS Task Force — to make sure regulations account for these real-world constraints. Honeydew’s CEO, Julian Belilty, serves as Co-Chair of that subcommittee and has been directly involved in shaping the compliance framework you’ll be navigating this year.

What Compliance Options Are Available?

DOEE has built multiple pathways for buildings that can’t hit the standard right now. Here’s a plain-English overview:

Achieve Full Compliance: Get your Energy Star Score to 66 or reduce EUI by 20%. Still achievable for many buildings, especially with a GFA verification (see below) or targeted energy projects.
Reinvestment Clause (Optional Agreement): If you’re penalized, your penalty dollars get reinvested 100% back into energy improvements at your building instead of going to DC. This is a new provision being finalized in the upcoming BEPS Guidebook.
Extended Deep Energy Retrofit (EDER): A long-term pathway for buildings that need more time to complete deeper efficiency work. Requires committing to a 40–50% energy reduction plan using all-electric upgrades.
Good Faith Effort (GFE): DOEE is finalizing a framework to recognize buildings that genuinely tried. Even if you haven’t hit the target, energy audits, LED upgrades, HVAC repairs, and board votes on energy projects since 2018 may all count toward qualifying.
Financial Distress Exemption: For buildings with documented financial hardship. Criteria are being revised to reflect community association realities, including reserve balances and special assessment constraints.

The Deadline You Cannot Miss: December 31, 2026

This is the hard stop for Cycle 1. December 31, 2026 is the deadline to submit:

Pathway applications (EDER, Reinvestment Clause)
Good Faith Effort applications
Financial Distress exemption requests
Delay requests

After this date, your options narrow significantly. Buildings that wait until the last minute often find they don’t have enough time to gather the documentation, coordinate with their board, or execute the energy projects needed to qualify for a pathway.

Not sure where your building stands? That’s exactly what we’re here for.

Honeydew Energy Advisors has helped over 1,100 DC buildings navigate benchmarking and BEPS compliance, and not one of our clients has received a penalty. We know the system, we’re at the table where the rules are being written, and we can help your building find the right path forward.