New York City is tightening its approach to building emissions as part of its wider climate goals. For many property owners, this brings new reporting requirements, clearer emissions limits, and the risk of financial penalties for exceeding those limits.
Local Law 97 is the city’s main building emissions law, applying to tens of thousands of large buildings. Understanding how the law works and what it means in practice is now a priority for owners, asset managers, and teams responsible for building portfolios.
What is Local Law 97?
Passed in 2019, Local Law 97, sometimes referred to as NYC Local Law 97 or LL97, is a climate law that limits greenhouse gas emissions from large buildings.
It focuses on buildings because they account for roughly two thirds of the city’s total emissions. Instead of a single citywide threshold, the law sets annual carbon limits based on building type and size. Emissions are measured in metric tons of CO₂-equivalent per square foot, and the limits become more stringent over time. This law aims to cut building emissions by around 40% by 2030 and move toward net zero by 2050.
Buildings that exceed their allowed emissions are required to pay a financial penalty.
How the emissions cap works
At the centre of the law is an annual emissions cap. In simple terms, each covered building has a maximum level of emissions it is allowed to produce in a year.
That cap is calculated by multiplying the building’s floor area by an emissions limit that applies to the occupancy type. If a building’s reported emissions are below the cap, it is compliant. If emissions exceed the cap, the penalty applies to the excess.
Compliance is not a one-time check. Emissions limits tighten significantly from 2030 onwards, which means buildings that meet today’s caps may still need upgrades to remain compliant in future periods. For teams managing portfolios with different building types and ages, this makes forward planning essential.
Which buildings does Local Law 97 apply to?
An estimated 50,000 buildings fall within scope across New York City.
In most cases, the law covers:
- Buildings over 25,000 square feet
- Groups of buildings on the same tax lot that together exceed 50,000 square feet
- Condo and co-op buildings where the combined floor area exceeds the threshold
Some building types have modified requirements or alternative compliance pathways, including certain affordable housing, houses of worship, and specific publicly regulated buildings. Coverage depends on building classification, so owners often need to confirm applicability carefully. You can find the list of covered buildings here.
Key requirements and timelines
Local Law 97 is structured around multi-year compliance periods, with emissions limits becoming stricter over time. The current timelines are:
- 2024-2029: First compliance period, with initial emissions caps
- 2030-2034: Significantly tighter limits for most building types
- 2050: Citywide target for net-zero building emissions
Annual emissions reports must be submitted showing actual greenhouse gas emissions compared to the allowed limit.
The first mandatory reporting cycle covered emissions from the 2024 calendar year, with reports due in May 2025 and a 60-day grace period into late June.
Reporting under Local Law 97 is annual and recurring, reinforcing the need for repeatable data processes rather than one-off calculations. This makes a consistent approach to data collection and reporting essential.
Penalties and risks of exceeding the emissions cap
If a building exceeds its emissions cap, the owner must pay a financial penalty based on the excess emissions.
Guidance from the NYC Department of Buildings sets the penalty at $268 per metric ton of CO₂-equivalent emissions above a building’s annual limit. As emissions limits tighten from 2030 onwards, a growing number of buildings are expected to fall out of compliance, increasing financial exposure for owners who delay action.
Beyond direct fines, how a building performs against its emission limits can also influence longer-term decisions by investors, lenders, and tenants, particularly for owners managing large or high-profile assets.
How can teams comply in practice?
Compliance typically starts with understanding a building’s current emissions and how they compare to the relevant caps. Once that is clear, it becomes much easier to prioritise action. Here are a few steps to get started:
- Assess current emissions
Owners usually begin by benchmarking energy use and calculating a baseline carbon footprint, including Scope 1 and Scope 2 emissions, which are the direct and energy-related emissions most relevant under Local Law 97. This helps to identify how far a building is from its emissions cap, and where the biggest emitters are.
For organisations managing multiple buildings, having consistent data across assets is essential for comparing performance and setting priorities.
- Prioritise upgrades that move the needle
Common measures include upgrading HVAC systems, improving insulation, switching to more efficient lighting, and installing better controls and automation. Many building owners are also replacing gas or oil-based heating, cooling and hot water systems with electric alternatives, such as heat pumps, to reduce on-site emissions.
- Identify operational improvements
Not all improvements require major capital to have an impact. Better scheduling, improved maintenance, and occupant engagement can also help to reduce emissions in the near term.
Taking early steps also supports longer-term planning, since the 2030 caps are tighter for many building types.
How Zevero supports Local Law 97 readiness
Zevero works with organisations managing portfolios of buildings to measure and manage their carbon emissions as part of regulatory and ESG requirements. The platform brings carbon data into one centralised place, supporting consistent measurement and comparison across assets and reporting periods.
Alongside the platform, Zevero’s climate experts support teams with methodology, data quality and documentation, helping ensure that emissions data is reliable year on year and useful for decision-making as caps tighten. You can learn more about the support we can offer here.
Checklist for teams
✓ Confirm which buildings are covered and which classifications apply
✓ Gather energy and fuel use data for each building
✓ Calculate emissions baselines and compare against current and future caps
✓ Identify which assets are closest to their cap and prioritise action accordingly
✓ Build a multi-year capital and operations plan aligned with LL97 timelines
✓ Revisit plans ahead of the 2030 compliance period, not just the first cycle
