LL97 Compliance: Key Deadlines and Avoiding Costly Penalties

LL97 Compliance: Key Deadlines and Avoiding Costly Penalties

New York City’s Local Law 97 (LL97) compliance deadline is fast approaching, and building owners who need more time to submit their reports must take action now. If you’re planning to apply for an extension, you need to have hired a Registered Design Professional (RDP) or a Retro-Commissioning (RCx) Agent (for Article 321 buildings) by February 1, 2025. Missing this step could result in significant financial penalties.

Understanding LL97 Deadlines and Penalties

LL97 compliance reports are due on May 1, 2025, but a 60-day grace period extends the final deadline to June 30, 2025. If your building falls under Article 320 and requires an annual emissions report, failing to file by June 30 will result in a monthly penalty of $0.50 per square foot. If the report is filed by June 30, the penalty will not apply. If the report is not filed by June 30, the penalty will be retroactive to May 1.

For example:

  • A 10,000-square-foot building that misses the May 1 deadline will face a $5,000 penalty for each month the report remains unfiled.
  • If the report is filed by June 30, there will be $0 penalty.
  • If the report is not filed by June 30, the penalty will be $10,000 ($5,000 for May and $5,000 for June), plus $5,000 per month for each additional month in which the report is not filed.

How to Apply for an Extension

If your RDP (or RCx agent for Article 321 buildings) is unable to complete the report by June 30, you may request an extension to August 29, 2025. However, to qualify, you must provide:

    A signed contract between you and the RDP/RCx agent, executed no later than February 1, 2025; and

  1. An affidavit signed by both you and the RDP/RCx agent stating that the report could not be completed on time and confirming it will be filed within 120 days of the original May 1 deadline.

Act now to avoid costly penalties and ensure your building remains compliant with LL97.

Update.