NYC energy code compliance requirements apply to nearly every new building and alteration permit filed in the five boroughs, and 1 RCNY 5000-01 is the rule that spells out what you submit, who signs it, and what inspections have to happen before the Department of Buildings signs off.1New York City Department of Buildings. 1 RCNY 5000-01 – Construction Document Approval Requirements for Compliance With the New York City Energy Conservation Code In short: a registered design professional files an energy analysis, stamped energy drawings, and a TR8 through DOB NOW: Build, the project goes through progress inspections during construction, and an EN2 at the end certifies the finished building matches the approved analysis. Applications filed on or after March 30, 2026 fall under the 2025 NYC Energy Conservation Code, which tightens several rules and ends the automatic exemption historic buildings used to enjoy.2NYC Buildings. Energy Conservation Code
Which Projects Need an Energy Filing
Every application a registered design professional files for a new building or an alteration must include a statement confirming the project either complies with or is exempt from the Energy Conservation Code.1New York City Department of Buildings. 1 RCNY 5000-01 – Construction Document Approval Requirements for Compliance With the New York City Energy Conservation Code That covers new construction, horizontal and vertical additions, and renovations classified as Level 1, Level 2, or Level 3 alterations under the existing building code. The alteration level depends on the extent of work relative to the overall building, and the higher the level, the more demanding the energy requirements become.
Not every job triggers a full review. Painting, caulking cracks, and routine maintenance that doesn’t replace a regulated component are generally excluded. But the line between maintenance and alteration is thinner than people expect. Swapping a few fixtures may clear the bar; replacing an entire lighting system almost certainly won’t. Figuring out the correct scope early prevents mid-project surprises that stall permits.
One boundary worth stating directly: starting with applications filed on or after March 30, 2026, there is no longer an automatic energy exemption for historic buildings. Any alteration of a historic property now requires an energy submission.3NYC Buildings. Service Notice – 2025 NYC Energy Conservation Code Guidance Teams working on landmark buildings that previously bypassed energy review need to budget for the added documentation and analysis.
Residential or Commercial: Pick the Right Path First
The energy code splits buildings into two tracks. Residential projects follow Chapters R2 through R6 of the Energy Conservation Code. Commercial projects follow either Chapters C2 through C6 or the ASHRAE 90.1 standard in its entirety, and once you pick a path, every document in the filing has to stay on it.1New York City Department of Buildings. 1 RCNY 5000-01 – Construction Document Approval Requirements for Compliance With the New York City Energy Conservation Code You cannot mix and match.
The residential label under the energy code generally covers detached one- and two-family dwellings and multifamily buildings three stories or fewer above grade.4U.S. Department of Energy. REScheck Everything else is commercial, including high-rise apartment towers and mixed-use buildings. Commercial tenant fit-outs count too, even interior-only office build-outs, if they involve regulated systems like HVAC or lighting.
For new commercial buildings 25,000 square feet or larger using the energy modeling approach, the envelope has to meet either the prescriptive requirements of ASHRAE 90.1 Section 5.5 or the calculated envelope performance factors under Appendix C.1New York City Department of Buildings. 1 RCNY 5000-01 – Construction Document Approval Requirements for Compliance With the New York City Energy Conservation Code Getting the classification wrong at the start means preparing the wrong analysis, running the wrong software, and submitting documents the plan examiner will reject.
What Goes in the Filing Package
The energy filing has three core pieces: the energy analysis, the energy drawings, and the TR8. Each one has to be internally consistent with the other two. Most delays trace back to a mismatch between them.
Energy Analysis
Every project that isn’t fully exempt needs an energy analysis identifying the compliance path and showing how the design meets the code.1New York City Department of Buildings. 1 RCNY 5000-01 – Construction Document Approval Requirements for Compliance With the New York City Energy Conservation Code Residential analyses typically run through REScheck,4U.S. Department of Energy. REScheck commercial through COMcheck.5Building Energy Codes Program. COMcheck The software calculates whether insulation values, window ratings, HVAC efficiency, and lighting power density meet the required thresholds, and produces standardized reports in the formats DOB expects.
For applications filed on or after March 30, 2026, you have to use the 2025 NYCECC version of the software rather than any earlier edition.2NYC Buildings. Energy Conservation Code The DOE moved COMcheck to a web-based platform updated in October 2025, and the legacy desktop version is being phased out.5Building Energy Codes Program. COMcheck
Energy Drawings
The architectural plans have to carry a prominent Energy Statement: a formal declaration by the registered design professional that the project complies with the code. Beyond that statement, the drawings themselves must clearly label insulation layers, vapor barriers, glazing specifications, and the locations of energy-efficient equipment described in the analysis. The drawings are the visual proof backing up the numbers in the software report. When the R-value on a wall section doesn’t match the R-value entered in COMcheck, the plan examiner flags it, and that kind of mismatch is one of the most common reasons for objections.
TR8
The TR8, formally the Technical Report Statement of Responsibility for Energy Code Progress Inspections, identifies who is responsible for conducting energy-related inspections during construction.6New York City Department of Buildings. TR8 – Technical Report Statement of Responsibility for Energy Code Progress Inspections The design applicant signs and seals the form, certifies which inspections are required and whether commissioning applies, and names the inspection agency accepting responsibility for each item.
Every inspection listed on the TR8 should correspond to a specific energy feature in the plans. Add insulation and there is an envelope inspection. Install ductwork and there is a duct leakage test. The TR8 is the thread connecting your approved plans to what actually gets built and verified on site.
Air Leakage Testing
Blower door testing is mandatory for new low-rise residential buildings, dwelling units proposing natural ventilation, and spaces undergoing a change in occupancy that increases energy demand. The building or unit must demonstrate an air leakage rate of no more than three air changes per hour at 50 Pascals of pressure, tested in accordance with RESNET/ICC 380, ASTM E779, or ASTM E1827.7New York State Department of State. Code Outreach Program – ACH 50 Testing
Buildings with two or more dwelling units sharing a single thermal envelope can use an alternative standard: no more than 0.3 cubic feet per minute per square foot of enclosure surface area at the same 50-Pascal pressure. For buildings with more than seven units using this alternative, the building official may allow representative sampling instead of testing every unit. Testing can happen any time after all envelope penetrations are complete, and a written report signed by the tester has to be included in the project documentation. The building official can require that the test be run by an approved third party rather than the contractor’s own team.
How You File and What It Costs
All energy code documents are submitted electronically through DOB NOW: Build, the city’s centralized system for job filings and permits.8New York City Department of Buildings. DOB NOW Build Energy Submission Step by Step Guide You upload the finalized energy analysis, the TR8, and the stamped energy drawings for electronic review. DOB provides step-by-step filing guides and resources specific to energy submissions.9NYC Department of Buildings. DOB NOW Build – Energy Submissions Resources
There is no separate energy-specific fee. Permit filing fees are set by building size, occupancy, and cost of work. A new one-, two-, or three-family dwelling runs $0.06 per square foot of total floor area, minimum $130. Other new buildings under seven stories and 100,000 square feet are charged at $0.26 per square foot, minimum $280. Alterations are typically charged by the cost of work: a minimum fee for the first few thousand dollars, plus an incremental rate per additional $1,000 of construction cost.10New York City Administrative Code. NYC Administrative Code 28-112.2 – Schedule of Permit Fees
If the plan examiner finds errors or missing information, an objection is issued and the design professional has to submit revised documents or clarifications. Addressing objections quickly matters because the energy approval is a prerequisite for the construction permit itself. An unresolved objection doesn’t just hold up the energy filing; it holds up everything downstream.
Changes After the Permit Is Issued
Construction rarely goes exactly as planned. When equipment specs change, materials become unavailable, or the design shifts, the city needs to know. A Post-Approval Amendment (PAA) is required for any significant change to the scope of work or the approved plans.11NYC Buildings. Post Approval Amendment (PAA) The applicant files a PW1 form with the Amendment option selected, describes the changes, and submits amended plans with the changes highlighted. Any previously filed PAAs affecting the same work type on the same document must be approved or withdrawn before a new one can be submitted, and withdrawing an open PAA costs $100.
For minor plan changes that don’t alter any information on the PW1 form, an AI-1 (Additional Information) form can be filed instead. If the change affects the energy analysis, though, the full PAA route is almost always the right one. A swapped HVAC unit or a different window product can change the whole compliance calculation. If the PAA is needed to correct an Environmental Control Board violation for work done contrary to the approved plans, the violation number has to be included in the filing.
Closing the Job Out: The EN2
Before the Department of Buildings will issue a sign-off or certificate of occupancy, the energy code progress inspections must be closed out. That requires completion of the EN2 (Certification of Conformance with As-Built Energy Analysis), in addition to the TR8.12NYC Department of Buildings. Progress Inspections The progress inspector certifies on the EN2 that the as-built conditions in the finished building match the values in the last-approved energy analysis.13NYC Department of Buildings. Energy Code Forms
If construction deviates from the approved analysis, the original preparer has to produce an as-built energy analysis reflecting what was actually installed. The progress inspector then certifies on the EN2 that the as-built values match this revised analysis. Here is the catch: if the as-built analysis fails to comply with the energy code, the inspector cannot complete the EN2, and the application will not be signed off. At that point the project is stuck until someone brings the building into compliance, whether that means replacing equipment, adding insulation, or some other corrective measure. This is why tracking substitutions and field changes throughout construction matters more than hoping it works out at the end.
Penalties for False or Negligent Filings
Submitting inaccurate energy compliance documents carries real consequences. Under the NYC Administrative Code, anyone who knowingly or negligently makes a false statement on a certificate, application, or report faces civil penalties of $2,500 to $10,000 for a first violation, and $5,000 to $10,000 for any subsequent violation.14New York City Administrative Code. NYC Administrative Code 28-211.1 – False Statements in Certificates, Forms, Written Statements, Applications, Reports, or Certificates of Correction The word “negligently” is doing a lot of work there. You don’t have to intend fraud; sloppy work that produces false numbers on the energy analysis or TR8 can trigger the same penalties.
Beyond fines, the Commissioner can notify the state licensing board responsible for the professional engineer or registered architect involved. A disciplinary referral can lead to license suspension or revocation. The professional of record who signs and seals the energy documents is personally on the hook for their accuracy, not just the firm or the project owner.