The Energize Denver ordinance requires commercial and multifamily buildings of 5,000 square feet or more to benchmark their energy use each year and meet energy performance standards on a schedule running through 2032, with fines for missed reports and, starting in late 2029, for missed performance targets. The rules were significantly rewritten in April 2025, cutting penalty rates, extending deadlines, and adding new flexibility options, so any guidance published before then is out of date. The ordinance is codified in the Denver Revised Municipal Code Title II, Chapter 10, Article XIV, and sits inside the city’s broader goal of reaching net-zero energy by 2040.
Which Buildings Are Covered
Coverage is based on total gross floor area from official assessor records. Buildings split into two tiers: 25,000 square feet and larger, and 5,000 to 24,999 square feet. The requirements differ sharply between them.
If you own a unit inside a larger building, you fall under the rules for the whole structure, not your individual unit. Mixed-use properties are evaluated by primary occupancy type, and campus-style developments may report as a single entity under certain conditions.
Several categories sit outside the ordinance entirely:
- Buildings that lacked a certificate of occupancy for the full 12-month reporting year, including properties under renovation for that entire period.
- Buildings with a demolition permit where work has already started before the compliance deadline.
- Properties in financial distress through a tax lien sale, court-appointed receivership, or deed in lieu of foreclosure.
- Stand-alone parking garages.
- Commercial power generation facilities that meet the Energy Star Portfolio Manager definition of an Energy/Power Station.
Two categories owners sometimes assume are exempt are not. Houses of worship are covered and have their own Energy Use Intensity targets. City-owned municipal buildings are explicitly included.
Requirements for Buildings 25,000 Square Feet and Larger
Large buildings must benchmark energy use annually through the Energy Star Portfolio Manager tool and meet Energy Use Intensity (EUI) targets, measured in energy consumed per square foot. Each building type has its own target.
The 2028 and 2032 Deadlines
Under the April 2025 revisions, large buildings must hit an interim performance target by 2028 and a final target by 2032. The older deadlines of 2024, 2027, and 2030 no longer apply. No building is required to reduce energy use by more than 42% from its baseline, regardless of building type.
Buildings that need more time can submit a long-term compliance plan to extend their deadline beyond 2032. A separate compliance hold lets buildings facing short-term problems, such as vacancy or financial distress, pause requirements for up to two years. Homeowners associations can align compliance planning with their capital improvement and fundraising schedules.
Annual Benchmarking
Every large building must submit benchmarking data every year. For the current cycle, 2025 energy data must be submitted and approved by June 1, 2026. Owners share the Portfolio Manager report with the City and County of Denver.
A $2,000 fine applies if the benchmarking report is not approved by the deadline. Failure to resolve or pay the citation can result in a lien on the property.
Renewable Energy as an Offset
Renewable energy can offset part of the EUI reduction, with rules that differ by contract term. Short-term contracts or subscriptions of at least 12 months can offset up to 20% of the building’s electricity usage through 2031, and are not allowed after 2032. Long-term installations or contracts of at least five years have no cap on the amount of electricity they can offset. The April 2025 changes opened eligible off-site solar locations to anywhere in Colorado, rather than only the Xcel Energy service territory, and added a 1.5x credit multiplier for renewable installations located inside Denver. Buildings connected to non-emitting thermal energy networks, such as district geothermal systems, receive an additional target incentive.
Requirements for Buildings 5,000 to 24,999 Square Feet
Smaller buildings follow a prescriptive path rather than tracking EUI. Owners can comply by certifying that at least 90% of the building’s total lighting load comes from LED lights, or that all lighting meets the 2019 Denver Building and Fire Code standards for lighting power density. Installing on-site renewable energy is an alternative pathway.
Documentation is submitted through the Energize Denver portal, with evidentiary requirements detailed in the city’s technical guidance documents.
When Gas Equipment Reaches End of Life
Separate from the EUI and lighting requirements, the ordinance applies to equipment replacement in all commercial and multifamily buildings, regardless of size. When certain gas-fired heating and cooling equipment fails, or when the owner pulls a permit for a new installation, the replacement must be an electric heat pump. Covered equipment includes packaged terminal air conditioners, unitary AC and condensing units serving heated spaces, gas furnaces, gas water heaters, boilers, and central hot water systems.
The requirement is conditioned on a “near cost parity” standard. A heat pump replacement must come within 5 to 15 percent of the cost of a like-for-like gas replacement, counting all available incentives and the social cost of carbon over the gas system’s lifetime. If the cost gap is larger, owners may qualify for an exception. An economic hardship exemption is available through at least 2027 for owners facing physical or financial barriers. If existing equipment has already exceeded 50% of its useful life, the April 2025 rules give owners more flexibility in replacement timing while still working toward efficiency targets.
Penalties
Two separate obligations carry fines: benchmarking and performance.
Benchmarking: a $2,000 fine when the annual report is not submitted and approved by June 1. Unpaid citations can lead to a property lien, which matters directly to anyone planning to sell.
Performance: fines are based on how far a building exceeds its EUI target. The original rate was $0.30 per kBtu of energy used above target, plus an inflation adjustment for each year past 2022. The April 2025 changes cut penalty rates in half and reduced the number of compliance deadlines that trigger penalties. No performance penalties will be assessed until late 2029.
Exemptions and Target Adjustments
Historic landmark buildings are covered but can apply for a customized pathway through a Historical and Unique Building Target Adjustment Application. If standard efficiency requirements would damage the historic character of the structure, the city may modify them.
Any building can request a custom target that adjusts the efficiency goal beyond standard adjustments. Adaptive reuse projects have a separate accommodation reflecting the constraints of converting existing structures. Manufacturing, agricultural, and industrial buildings have an adjusted energy use floor of 52.9 kBtu per square foot per year, raised from the original 30 kBtu floor.
Financial Help for Owners
Buildings classified as “under-resourced” get priority access to support. A property qualifies if at least 50% of its gross floor area is income-qualified multifamily housing, if it houses a nonprofit or house of worship with demonstrated financial need, or if it is in financial distress such as tax foreclosure or recent bankruptcy. Support includes one-on-one coaching, priority access to grants, and potential exemptions or deadline extensions where financial constraints prevent compliance.
The Energize Denver Compliance Assistance Gap Fund provides up to $50,000 to qualifying buildings 25,000 square feet and larger. Awards are paid in two parts: up to 50% at project start, with the remainder on completion once permits, installation verification, and updated invoices are documented. The current application window closes September 30, 2026.
Colorado’s Commercial Property Assessed Clean Energy (C-PACE) program is a separate financing route. C-PACE can cover up to 100% of project costs for energy reduction and on-site generation, with repayment typically running 10 to 20 years and attached to the property’s tax assessment. Mortgage lender consent is usually required.
Selling a Covered Building
Energize Denver obligations run with the building, not the owner. Existing compliance plans and any unpaid penalties transfer to the buyer, which makes compliance status a real factor in valuation.
Sellers must disclose the following in all advertising and sale documentation:
- Current benchmarking compliance status.
- The building’s current Energy Use Intensity metric.
- Future energy efficiency targets.
- Any approved target adjustments or alternate compliance options.
- Copies of existing compliance plans.
After closing, the seller must transfer the Energy Star Portfolio Manager account to the buyer so the building’s energy tracking and compliance history stays intact. Owners should also check that lease agreements require tenants to share utility data, since whole-building data is required for benchmarking and tenants often control individual meters.
How to File
Large building owners benchmark through Energy Star Portfolio Manager and share the report with the City and County of Denver by linking the building profile to the city’s Portfolio Manager account. Smaller building owners upload verification documents through the Energize Denver portal.
Forms are available through the Denver Office of Climate Action, Sustainability, and Resiliency, and were updated as of April 1, 2025 to match the new rules. Owners should have the building’s verified gross floor area, 12 months of electricity and natural gas or steam usage data, and documentation for any renewable energy credits or off-site solar subscriptions. Many utilities offer automated data transfer directly into Portfolio Manager, which cuts out manual entry errors. The system generates a confirmation receipt on submission, and the city reviews the report for consistency before marking the building compliant for that year.