What Is Local Law 97 and How Does It Affect NYC Building Owners?

Learn how NYC’s Local Law 97 affects building owners in 2025. Learn compliance steps, penalties, and expert solutions to reduce emissions and avoid fines.

Jul 2, 2025 - 19:20
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What Is Local Law 97 and How Does It Affect NYC Building Owners?
NYC Local Law 97 Consultants

To reduce carbon emissions and fight climate change, New York City introduced Local Law 97 as part of its Climate Mobilization Act in 2019. This law sets carbon emissions limits on large buildings—residential, commercial, and institutional—across the city. The goal is to cut NYC’s greenhouse gas emissions by 40% by 2030 and 80% by 2050, compared to 2005 levels.

Local Law 97 (often referred to as LL97 NYC) is now one of the most significant environmental regulations affecting property owners in New York City. With deadlines approaching and fines becoming a reality, it's crucial for building owners to understand how this law works, who it affects, and what actions are necessary to stay compliant.

 

Who Does Local Law 97 Apply To?

Local Law 97 applies to:

  • Buildings over 25,000 square feet
  • Two or more buildings on the same tax lot that together exceed 50,000 square feet
  • Two or more buildings in the same condominium that together exceed 50,000 square feet

That means over 50,000 buildings in NYC are subject to LL97. This includes commercial towers, co-op and condo buildings, hospitals, educational institutions, and more.

 

What Are the Emissions Limits?

Starting in 2024, buildings must comply with the carbon emissions limits set by the law. These limits are measured in metric tons of CO₂ equivalent per square foot. The limits vary based on building type (e.g., residential, office, hospital) and are phased in across compliance periods.

Emissions Compliance Periods:

Period

Years

Key Focus

1

2024–2029

Initial enforcement phase with moderate limits

2

2030–2034

Much stricter limits

3+

2035 onwards

Progressively tighter caps

Buildings that exceed their carbon limits must pay penalties unless they qualify for an exemption or take corrective action.

 

What Happens If You Don’t Comply?

If a building emits more greenhouse gases than allowed, the owner must pay $268 per metric ton of CO₂ over the limit—annually.

For example:

If your building exceeds the emissions limit by 100 tons in 2025, you’ll be fined $26,800 per year.

In addition to fines, building owners must also file an annual emissions report certified by a registered design professional (PE or RA). Failing to file on time can result in additional penalties of $0.50 per square foot per month.

 

Exemptions and Special Cases

While Local Law 97 affects most large buildings, some are partially exempt or treated differently, including:

  • NYCHA (public housing)
  • City-owned buildings (subject to their own emission reduction mandates)
  • Houses of worship
  • Certain rent-regulated units (although they still need to perform energy upgrades)

Buildings can also apply for adjustments or exemptions due to financial hardship, low occupancy, or other factors—but the approval process is strict and time-bound.

 

What Are Your Compliance Options?

There are several ways building owners can reduce their emissions and meet LL97 targets. The right strategy depends on your building’s current energy use, systems, and infrastructure.

1. Energy Audits and Retro-Commissioning

Start with an energy audit (required by Local Law 87) to identify areas of waste. Retro-commissioning ensures building systems operate efficiently. Together, they provide a roadmap for upgrades.

2. Upgrade Heating and Cooling Systems

Switch from fossil fuel-based boilers to electric heat pumps, which are more energy-efficient and cleaner.

3. LED Lighting and Controls

Replacing outdated lighting with LED fixtures and smart controls significantly cuts electricity use.

4. Insulation and Window Replacements

Better building envelope performance reduces heating and cooling loads, helping you cut emissions.

5. Renewable Energy

Installing on-site solar panels or purchasing clean energy credits (RECs) can help reduce your carbon footprint.

6. Submetering and Data Monitoring

Installing submeters in tenant spaces helps track energy use and promote accountability.

 

New Updates and Enforcement for 2025

As of July 2025, the NYC Department of Buildings (DOB) has already issued thousands of violation notices to buildings that failed to submit their emissions reports for 2024. The DOB has also released the Carbon Emissions Calculator Tool, which helps owners understand their current emissions and forecast penalties.

A new LL97 Advisory Board Report, released in May 2025, suggested more flexible pathways to compliance, especially for buildings under construction or with low occupancy post-COVID. But the enforcement is still aggressive—compliance is not optional.

 

LL97 and Sustainability Goals

Local Law 97 is more than just a rule—it’s a foundational part of NYC’s fight against climate change. Buildings are responsible for nearly 70% of the city's carbon emissions, so this law targets a major contributor.

By requiring emissions cuts, LL97 is also:

  • Improving building performance
  • Boosting property values through energy upgrades
  • Creating thousands of green jobs
  • Supporting cleaner air and healthier neighbourhoods

 

How to Get Started

If you're a building owner, don’t wait for a violation notice. Start now by:

  1. Benchmarking your building’s emissions (via ENERGY STAR Portfolio Manager)
  2. Hiring a qualified energy consultant
  3. Reviewing your utility data and HVAC systems
  4. Creating a compliance plan with deadlines and budget
  5. Applying for exemptions if eligible

The earlier you act, the more options you have to avoid fines and meet your sustainability goals.

 

Work With a Local Law 97 Consultant

Staying compliant with Local Law 97 can be complex—but you don’t have to do it alone. A Local Law 97 Consultant Service can help you:

  • Perform energy audits
  • Navigate DOB reporting requirements
  • Select cost-effective energy upgrades
  • Apply for hardship adjustments or credits
  • Track emissions and plan for future phases

Partnering with a consultant ensures your building remains compliant while saving on energy and maintenance costs.

 

Conclusion

Local Law 97 is changing how New York City buildings operate. For owners of large buildings, it's no longer just about comfort and cost—it’s about compliance, climate, and the future of urban sustainability.

With enforcement underway in 2025, now is the time to take LL97 seriously. By making smart upgrades today, building owners can reduce emissions, avoid penalties, and future-proof their properties.

Need help with compliance? Reach out to a trusted Local Law 97 Consultant to start your plan today.

 

thecotocongroup.com Sustainability Consulting Experts in NYC. Leading the Real Estate Industry in Reducing GHG Emissions & Increasing Property Value.