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New York City’s Department of Buildings reported that 95% of properties filing under Local Law 97 met the requirements for 2024, the law’s first compliance year. About 7% of the 29,031 properties required to report missed the August 2025 deadline, and the city says it is pursuing enforcement against those that have not filed.
New York City’s Department of Buildings said 95% of properties that filed their first Local Law 97 reports met the requirements for 2024, the city’s first compliance year under the emissions law. The agency’s results report, released September 14, also says 1,911 of 29,031 required properties had not filed by the August 29, 2025 deadline, and the city is pursuing enforcement against them.
The reported 95% compliance rate applies to properties that filed, not to every property required to report. Under the city’s figures, 7% of required properties missed the deadline. Some late properties may still submit reports, Deputy Commissioner of Sustainability Laura Popa said during a webinar hosted by the Urban Green Council. She described a little over 1,000 properties as still not filed at that point, while the report gives 1,911 as the total that missed the deadline; the figures refer to different points or stages in the reporting process.
Two compliance paths applied in the first year. Article 320 generally covers market-rate buildings across different uses and requires annual emissions reporting. The Department of Buildings said more than 9,950 Article 320 properties met their 2024 emissions limits. It counted 470 properties above their limits; 32% exceeded them by less than 10%, while 197 were reported between 10% and 50% over. The agency said many owners used upgrades such as improved lighting, building-envelope work, heat pumps and energy-management systems to meet the limits.
Article 321 offers an alternative one-time obligation for eligible affordable housing properties and houses of worship. More than 83% of Article 321 filing properties used its prescriptive route, which requires at least 13 specified energy and emissions improvements. Among properties using the performance route, more than 90% reported already meeting the law’s more stringent 2030 limits, according to the department. These figures describe reported compliance and performance; the source material does not detail independent verification of each property’s work.
Enforcement Follows First-Year Filings
The results provide an early measure of how building owners are responding to a city law that applies to most buildings larger than 25,000 square feet. Buildings account for a substantial share of the emissions targeted by New York’s climate policy, and the law requires owners to track and limit emissions or meet an applicable alternative pathway. The first-year filing and compliance figures show broad participation among filers, while the missing reports and properties over limits leave a continuing enforcement workload.
The city says it is using notices of deficiency and fines to address nonfiling and violations. For owners, the report also signals that upgrades and energy-efficiency work can be part of meeting the limits, while eligible properties may seek penalty mitigation if they can demonstrate good-faith efforts. The results do not establish how much citywide emissions fell as a result of the first compliance year.
Two Paths Governed 2024 Reporting
Calendar year 2024 was the first compliance year under Local Law 97, part of New York City’s climate legislation. Covered owners had to report their compliance to the Department of Buildings by August 29, 2025. The first-year reporting requirements covered Article 320 and Article 321, which apply different standards to different types of properties.
Article 320 covered roughly 11,000 properties, encompassing almost 17,000 buildings, in 2025. The department said multifamily housing made up 45% of these properties, with offices accounting for 17%; hotels, schools and non-refrigerated warehouses were among other reported categories. Some affordable housing buildings have later reporting start dates, in 2027 or 2036, depending on the program. Article 321 allows qualifying affordable housing properties and houses of worship to satisfy a one-time obligation through emissions performance or specified conservation measures.
The law also allows eligible owners to use certain offsets, deductions and alternative calculations. The city report lists 79 properties using Affordable Housing Reinvestment Fund offsets, 31 using solar, 10 using combined heat and power, and six using beneficial electrification credits. These options were used by a small number of properties compared with the overall reporting pool.
“Many improved their performance to meet limits through building upgrades and energy-efficiency measures, like lighting upgrades, envelope work, installing heat pumps or implementing building and energy management systems.”
— Emily Hoffman, director of Building Energy & Emissions Performance at the New York City Department of Buildings
Late Filings and Emissions Impact
The department’s results establish filing and reported compliance rates, but do not quantify the citywide emissions reduction attributable to the law in 2024. The source report also does not specify how many of the 1,911 properties that missed the deadline later filed, received notices, or faced fines. Popa’s webinar estimate of a little over 1,000 properties still outstanding was given at a particular point in the process, and the material does not state its date relative to the report’s total.
It is also not clear from the available results how many reported upgrades were completed and independently checked, or how many penalty-mitigation requests were ultimately granted. About 32% of properties above Article 320 limits requested mitigation; among 149 requests cited by Popa, more than two-thirds selected decarbonization plans. A request is not the same as an approved penalty reduction.
City Pursues Outstanding Reports
The Department of Buildings says it is pursuing enforcement against owners who have not filed and is addressing deficiencies through notices and fines. Owners seeking penalty mitigation can submit evidence of good-faith efforts, Popa said, including documentation of work underway, a decarbonization plan through 2050, or coordination with a utility to increase electrical capacity.
The next milestones are the resolution of late filings and enforcement cases, along with future annual reporting under Article 320. The first-year results provide a baseline for those steps; the department’s published figures do not yet show the final number of late properties or the emissions outcome after enforcement and completed work.
Key Questions
What did New York City report about Local Law 97 compliance?
The Department of Buildings said 95% of properties that filed met the applicable 2024 requirements. That percentage applies to filers, not all properties required to report.
How many properties missed the reporting deadline?
The city said 1,911 of 29,031 required properties had not filed by the August 29, 2025 deadline, equal to about 7% of those required to report.
Which buildings are covered by the law?
Local Law 97 generally covers most buildings larger than 25,000 square feet. Article 320 applies broadly to market-rate buildings, while Article 321 provides a different route for qualifying affordable housing properties and houses of worship.
What can owners do if their building exceeded its emissions limit?
Eligible owners can use options allowed by the law, such as certain offsets or alternative calculations, and may request penalty mitigation by showing good-faith efforts. The department said examples include work underway or a decarbonization plan; a request does not mean mitigation has been approved.
Does the report show how much emissions fell?
No citywide emissions reduction attributable to the first compliance year is stated in the available results. The figures focus on filing, reported compliance and use of alternative pathways.
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