From the field: As we’re actively benchmarking many new Maryland buildings right now, we’ve received fresh updates from MDE that are too important not to keep to ourselves. If you still need help getting your properties benchmarked (or just want a second set of eyes), Honeydew can jump in and get you across the finish line—fast.
Quick self-check: Want to see if your property is on the Maryland Covered Building List and download a tailored report with everything you need?
Get a free MD BEPS Compliance Report here: https://bepsmd.honeydewadvisors.com/
Now for the updates…
TL;DR (the essentials)
- Benchmark now. For 2025 only, submissions made by September 1, 2025 are treated as on time.
- HB49 adds new exemptions, exclusions, and credits starting October 1, 2025 (with a broader rule update expected in 2027).
- Statewide (non-MoCo) Even if you expect to be newly exempt on Oct 1, 2025, you must submit your 2025 benchmarking to MDE (2024 data) now—this streamlines October exemptions.
- Montgomery County (MoCo): If you submit your 2025 benchmark (2024 data) to DEP, you’re treated as compliant with Maryland BEPS for 2025—no separate MDE submission. Starting Oct 1, 2025, covered MoCo buildings follow County BEPS (not State).
- Condo rule: An individual condominium building < 35,000 ft² (excluding parking garage area) does not have to submit a benchmarking report.
- New fee: A $100 annual reporting fee (inflation-adjusted) begins in 2026. If you’re benchmarking through Honeydew, don’t worry—we’ve got you covered. We include this in our annual pricing—unlike some competitors.
What to do right now (Summer 2025)
If your buildings are outside Montgomery County
- Submit 2025 benchmarking to MDE by Sept 1, 2025 (2024 data in ENERGY STAR Portfolio Manager).
- Even if you expect a new exemption on Oct 1, benchmark this year to keep your status clean and speed up October filings.
- If you’ve already filed a legitimate exemption request, you’re treated as compliant while it’s reviewed; if denied, submit any prior-year reports by June 1, 2026.
If your buildings are in Montgomery County
- Submit your 2025 benchmark to DEP (County program). That satisfies Maryland BEPS for 2025—no duplicate State filing.
- Data handoff: Per MDE, you don’t need to add the MDE UBID to your MoCo submission at this time (if it’s already there, that’s fine).
- Deadline alignment: If DEP treats your submission as timely, MDE will as well.
- Beginning Oct 1, 2025, follow MoCo BEPS (not State) if your building is covered by the County program.
HB49 highlights starting October 1, 2025
- New exemptions, exclusions, and credits go live (MDE will roll out forms; these will also inform the 2027 regulation update).
- State–County alignment: Covered MoCo buildings are waived from State BEPS going forward and must comply with DEP rules instead.
Coverage basics (quick refresher)
- Covered buildings (State): Generally ≥ 35,000 ft² gross floor area (GFA)—exclude parking.
- Condominiums:
- A single condo building < 35,000 ft² (excluding parking) is not required to benchmark.
- Garden-style Associations may still be covered if multiple buildings share meters/central equipment that push the total combined GFA ≥ 35,000 ft² or if any individual building on campus has a GFA ≥ 35,000 ft².
- GFA definition: Area between the principal exterior surfaces of the enclosing fixed walls.
Key dates (save these)
- Now → Sept 1, 2025: 2025 benchmarking window; Sept 1 counts as on time this year.
- Oct 1, 2025: HB49 changes take effect; MoCo buildings pivot to County BEPS (if covered).
- 2026: $100 annual reporting fee begins (inflation-adjusted). If you’re benchmarking through Honeydew, don’t worry—we’ve got you covered. We include this in our annual pricing (AS EXPECTED!)—unlike some competitors.
How Honeydew makes this easy
- Full-service benchmarking: Portfolio Manager setup, utility data pulls, QA, and submission (MDE and MoCo DEP).
- Exemptions & credits: We screen eligibility and handle the filings as soon as MDE opens the forms.
- No surprises: We include the State’s $100 reporting fee starting in 2026—clean budgets, no gotchas.
- Forward planning: Step-by-step roadmaps and guidance so future performance requirements don’t become fire drills.
Need help before Sept 1?
Send us your property address(es), we’ll confirm coverage, outline next steps, and handle the submission so you can get back to running your portfolio.
Double-check coverage anytime. Look up your building and download your MD BEPS Compliance Report: https://bepsmd.honeydewadvisors.com/