DC Council Sticks to BEPS Deadlines – Here’s What That Means for You

It’s been a wild summer for DC’s budget process. In May, the Mayor floated a plan to pause the Building Energy Performance Standards (BEPS) and push off the Net‑Zero Energy code. That proposal made plenty of headlines and led some building owners to wonder whether they could slow down their energy improvements.

Not the headline most boards were hoping for: the pause didn’t happen. When the FY26 Budget Support Act was finalized on July 28, 2025, the DC Council removed the proposed BEPS/Net-Zero delays. That means the original timelines stay in force. If your building is covered by BEPS, treat the existing deadlines as firm and keep your compliance work moving.

What’s on the DC BEPS timeline?

Think of BEPS as a series of compliance cycles. Cycle 1 covers buildings ≥50,000 square feet of gross floor area (GFA); Cycle 2 will phase in buildings ≥25,000 sq ft, and Cycle 3 brings in buildings ≥10,000 sq ft. 

Here are the key dates:

• Finish your retrofits by December 31, 2025. To qualify for compliance, work (HVAC upgrades, lighting retrofits, envelope improvements, solar, etc.) needs to be installed and operational by the end of 2025. This isn’t an explicit legal requirement, but without it you won’t have a full year of energy savings during 2026.
  
  
• BEPS Period 1 deadline – Dec 31, 2026. Buildings need to meet their chosen compliance pathway by the end of 2026.
  
  
• DOEE review in 2027. By May 1, 2027, your calendar year 2026 benchmarking report is due, BEPS evaluation year. The Department of Energy & Environment (DOEE) will review your 2026 benchmarking to verify compliance.
  
  
• BEPS Period 2 starts Jan 1, 2028. Smaller buildings (>25,000 sq ft) enter the program then.
  
  

BEPS cycle summary

Note: the “evaluation year” is when DOEE reviews your benchmarking data to confirm compliance.

What this means for you

Even though the proposed “pause” grabbed headlines, nothing has changed. BEPS deadlines are moving ahead. Here’s how to stay on track:

• Keep your projects on schedule. If you need to install efficient boilers, upgrade controls, or add rooftop solar to hit your compliance target, aim to complete and commission those upgrades by December 31, 2025.
  
  
• EDER (Extended Deep Energy Retrofit): Trade more time for deeper, whole-building savings by committing to a multi-year retrofit plan with enforceable milestones (often extending into the next cycle); ideal for communities planning major capital replacements and needing runway to comply. 
  • Move quickly: to use EDER in Cycle 1, you must submit a complete application, receive DOEE approval and complete certain milestones (energy audit + implement at least one energy conservation measure) before Cycle 1 ends, with foundational items like a preliminary scope & savings analysis, milestone schedule, financing approach, and M&V plan. Once approved, you get a longer runway with annual check-ins.
    
    
• Financial distress relief (whole-cycle exemption): If your condo/co-op is genuinely strained, D.C. Law 25-307 allows a whole-cycle BEPS exemption. DOEE is finalizing guidance with a 30-day written comment period and hopefully targeted condo/co-op sessions. 
  • Prepare in advance: compile audited financials, reserve studies, delinquency/cash-flow summaries, insurance spikes, and near-term capital obligations; have counsel join your board review.
    
    
• Stay informed. Budget modifications could still affect Sustainable Energy Trust Fund programs and other incentives through DCSEU, so keep an eye on Honeydew updates. Take advantage of the DCSEU incentives while they’re still there!
  
  
• Benchmark early and often. Verify that your utility data flows correctly into ENERGY STAR Portfolio Manager so you’re ready for the full‑year benchmarking period in 2026.
  
  
  

Next steps (your energy consultant’s advice)

1. Schedule a BEPS check‑up. Conduct or update an energy audit to understand where your building stands relative to the BEPS threshold. This will determine which path makes sense.
   
   
2. Line up financing. Explore incentives through the DC Sustainable Energy Utility (DCSEU) for energy upgrades.
   
   
3. Prioritize quick wins. Low‑cost measures like recommissioning HVAC controls, sealing envelope leaks, or installing LEDs can make a big dent in your EUI.
   
   
4. Go solar before windows close. If your condo or co-op board is thinking about solar, now’s the time to act. Whether you’re leaning toward a Power Purchase Agreement (PPA), a roof lease, or owning the system outright, the key is to lock in your agreement by November 1. After that date, your ability to secure the current federal tax credit is likely to diminish, and the terms you’re offered may not be nearly as attractive. In other words, to maximize savings and lock in the best incentives, let’s get that solar plan in motion before October 1. We’re here to help you navigate the options and find the right fit for your community.
   
   
5. Reach out for help. Navigating BEPS and net‑zero requirements can feel overwhelming. Honeydew Energy Advisors helps condos and co‑ops benchmark buildings, evaluate upgrade options, secure incentives, and stay on top of shifting policies. Give us a call to discuss your path to compliance … and savings!
   
   

With the “pause” debate behind us, now is the time to double‑down on energy performance. Investing in efficiency today not only keeps you compliant with BEPS DC but also lowers operating costs and improves comfort for residents. Don’t wait until the last minute – let’s get your building on the road to a cleaner, more resilient future.