California’s benchmarking requirements, set by Assembly Bill 802, require owners of large commercial and multifamily buildings to report annual energy use to the California Energy Commission (CEC). Commercial buildings larger than 50,000 gross square feet are covered. Multifamily buildings are covered when they exceed 50,000 gross square feet and have 17 or more residential utility accounts.1California Energy Commission. Building Energy Benchmarking Program The obligation sits with the building owner of record, and the deadline is June 1 each year for the prior calendar year’s data.
A 60-unit apartment complex where each unit has its own electric meter will likely cross the residential-account threshold. A 20-unit building on a single master meter almost certainly will not. For purely commercial properties, square footage is the only trigger.2California Legislative Information. California Public Resources Code 25402.10
Buildings That Are Exempt
Several categories of otherwise-covered buildings can be excluded from reporting:3California Energy Commission. Building Energy Benchmarking Program Frequently Asked Questions
- Buildings where more than half the gross floor area is used for manufacturing, industrial purposes, or scientific experiments requiring a controlled environment.
- Buildings that lacked a certificate of occupancy, or a temporary certificate, for more than half the reporting year.
- Buildings scheduled for demolition within one year of the reporting date.
- Buildings substantially destroyed by unforeseen events, including those in a geographic area where multiple buildings were damaged by the same disaster.
- Condominium buildings structured under California Civil Code.
- Buildings located within Indian country as defined by federal law.
Exemptions are not automatic. If you believe your building qualifies, the CEC’s FAQ page explains how to document and submit the request.
What You Report
Only energy data is required. You submit consumption figures for electricity, natural gas, steam, or fuel oil covering the full prior calendar year.2California Legislative Information. California Public Resources Code 25402.10 Water and waste fields exist in Portfolio Manager but are optional; missing entries there will not block a valid submission, even if the Data Quality Checker flags them.3California Energy Commission. Building Energy Benchmarking Program Frequently Asked Questions
You also enter building characteristics: property type, gross floor area, operating hours, and location. Portfolio Manager uses those inputs to calculate energy use intensity and, for eligible property types, an ENERGY STAR score.
How to Submit
All submissions run through the EPA’s ENERGY STAR Portfolio Manager, which the CEC has designated as the required tool.4ENERGY STAR. Benchmark Your Building With Portfolio Manager If you don’t already have an account, create one and enter each reportable building as a separate property.
Getting Energy Data From Your Utility
California law requires electric and gas utilities to keep at least 12 months of consumption data in a Portfolio Manager-compatible format and to upload that data on the owner’s written or electronic authorization.2California Legislative Information. California Public Resources Code 25402.10 For buildings where individual tenants pay their own bills, the utility provides whole-building aggregated data so tenant-level usage stays confidential.
Start early. Utilities can take several weeks to process a data-sharing authorization, and the setup often requires forms, portal access, and coordination with property managers.
Adding Your Benchmarking Reference Number
Since 2023, every covered building has a benchmarking reference number (BRN) that ties your Portfolio Manager property to the CEC’s records. Look up your building’s BRN at benchmarkingca.com and enter it in the “Unique Identifiers” section of your property in Portfolio Manager before submitting.3California Energy Commission. Building Energy Benchmarking Program Frequently Asked Questions A missing BRN is a common reason submissions get rejected or flagged as incomplete.
Running the Data Quality Checker and Submitting
CEC regulations require you to run Portfolio Manager’s Data Quality Checker before submitting. It flags implausible readings and missing property details. Once the property is clean, go to the CEC’s Report Benchmarking Data page, click the appropriate reporting link, log into Portfolio Manager, and submit through the tool’s interface. The data transfers electronically to the CEC.
The June 1 Deadline
June 1 every year, covering the prior calendar year’s energy data. Owners in a jurisdiction with an approved local benchmarking ordinance do not file separately with the CEC. The local program collects the data and forwards it to the state.1California Energy Commission. Building Energy Benchmarking Program
Cities That Handle Their Own Reporting
As of the most recent CEC listing, buildings in these cities report to the local program rather than to the state:5California Energy Commission. Exempted Local Benchmarking Ordinances
- Berkeley
- Brisbane
- Chula Vista
- Los Angeles
- San Diego
- San Francisco
- San Jose
Local deadlines and submission requirements may differ from the state’s June 1 date, and each ordinance carries its own enforcement mechanism. Check with the city program directly.
Your Data Becomes Public
The CEC publishes energy performance data for reporting buildings on a public dashboard where anyone can search, view, and download building-level information.1California Energy Commission. Building Energy Benchmarking Program Both commercial buildings and multifamily buildings with 17 or more residential accounts are posted after each June 1 deadline. Prospective tenants, buyers, lenders, and competitors can see how the building performs against similar properties.
What Happens If You Don’t Report
The CEC enforces the requirement under the general enforcement authority in Public Resources Code Section 25321.2California Legislative Information. California Public Resources Code 25402.10 Before assessing any penalty, the CEC must notify you of the violation and give you 30 days to submit the required report.3California Energy Commission. Building Energy Benchmarking Program Frequently Asked Questions After that window, the CEC can assess civil penalties.
The statute contains one important protection for owners: if your non-compliance results from a utility’s failure to provide the required energy data, you are shielded from liability. Documentation of your data request and the utility’s delay is what makes that defense work, so keep records of every authorization form, portal request, and follow-up.