If you own, manage or lease a large building in the City of Philadelphia, two city rules shape your energy calendar: the Building Energy Benchmarking program, which asks for an energy and water report every year, and the Building Energy Performance Policy (BEPP), which asks for a building tune-up every five years. Both are run by the City's Office of Sustainability, both carry fines, and the second group of buildings under BEPP (100,000 to 200,000 square feet) has a compliance year in 2027. This guide explains who is covered, what is due when, and how to get ready without a last-minute scramble.
Two programs, two different clocks
It helps to keep the two requirements separate in your head, because they cover slightly different buildings and run on different cycles.
- Benchmarking (every year). According to the City, commercial and multifamily buildings of 50,000 square feet and larger must report whole-building energy and water use for the previous calendar year by June 30.
- BEPP tune-ups (every five years). The City's Building Energy Performance Program applies to non-residential buildings with at least 50,000 square feet of indoor floor space. Owners either complete a tune-up or certify as a high-performance building, then repeat the process with a new report every five years.
Note the difference: large multifamily buildings benchmark every year, but BEPP tune-ups apply to non-residential buildings. Both rules apply only to buildings inside the City of Philadelphia. Owners in Chester County and the rest of Southeastern Pennsylvania are not covered, although many use the same benchmarking tool voluntarily to track costs and emissions.
Annual benchmarking: what to submit and how
Benchmarking is done in ENERGY STAR Portfolio Manager, the U.S. EPA's online tool that compares a building's energy use to similar buildings nationwide. The City describes three basic steps:
- Gather the building's energy and water bills for the previous calendar year (January 1 to December 31).
- Log in to Portfolio Manager (first-time users create an account) and enter the data.
- Share the property's data with the City of Philadelphia before June 30.
Late reports carry a $300 fine after the first 30 days past the deadline, and if the report is still missing after that, an additional $100 per day until it is submitted, per the City's benchmarking page. Some buildings can be exempt, for example after a change in ownership that leaves the owner without a full calendar year of bills. The City offers remote office hours and help at benchmarkinghelp@phila.gov.
Common benchmarking mistakes
- Missing meters. Tenant-paid electric or gas accounts are easy to leave out, which understates whole-building use.
- Wrong floor area or property type. These drive the ENERGY STAR score, so check them against your building records.
- Forgetting to share. Entering data is not the same as submitting it; the property must be shared with the City.
- Waiting for June. Utility data requests can take weeks. Starting in the first quarter leaves time to fix gaps.
BEPP tune-ups: the compliance schedule
BEPP staggers deadlines by building size. The City's compliance deadlines page lists the current cycle:
- Over 200,000 sq. ft.: 2026 (tune-up report due September 30, 2026)
- 100,000 to 200,000 sq. ft.: 2027
- 70,000 to 100,000 sq. ft.: 2028 (tune-up report due October 2, 2028)
- 50,000 to 70,000 sq. ft.: 2029 (tune-up report due October 1, 2029)
For the 2027 group, the City lists these key dates:
- January 4, 2027: first day to submit Alternative Compliance Plans.
- April 5, 2027: first day to file for an exemption or request an extension; High Performance reports are due.
- September 30, 2027: tune-up report due, and tune-up specialists submitting 2027 reports must be certified by this date.
Missing a deadline results in a $2,000 fine, and the City's program page notes that an additional $500 per day accrues after the first 30 days until the building complies. Paying the fine does not remove the obligation to file.
What a building tune-up involves
The City describes a tune-up as a review of energy systems and controls, followed by adjustments that bring them to good performance. The City's BEPP FAQ lists the base building systems in scope: the building envelope, HVAC, conveying systems, domestic hot water and electrical lighting. The assessment looks at items such as utility bill analysis, sensors, schedules, setpoints, outside air control, equipment controls and maintenance.
Two roles matter:
- The tune-up specialist must hold a Professional Engineer (PE) or Certified Energy Manager (CEM) credential, have seven years of related education and experience, and be approved by the Office of Sustainability. Approved specialists are listed on the City's platform. The FAQ states the specialist generally must be a third party, not an employee, with a limited exception for large portfolio owners.
- The building operator (in-house staff or a contracted service provider) carries out the corrective actions, and the specialist verifies that the work addresses the recommendations.
The specialist also verifies the building's data in Portfolio Manager, so clean benchmarking makes the tune-up smoother.
The high-performance pathway
Instead of a tune-up, owners can certify the building as high performance. The City's FAQ lists options that include, among others, ENERGY STAR certification with a score of 75 or greater, demonstrated energy savings of at least 15%, participation in a utility retro-commissioning program, or an ASHRAE Level II energy audit with low-cost measures implemented. The FAQ also says the building must have complied with benchmarking for the two consecutive years before its tune-up compliance date and must demonstrate high performance at least six months before the deadline. Because the City amended its BEPP regulations in 2024, confirm the current criteria in the City's BEPP knowledgebase or with TuneUps@phila.gov before you choose this route.
A practical readiness checklist for 2027 buildings
- Confirm your size band and building type. Use your recorded gross floor area to confirm which year applies and whether BEPP covers the building.
- Clean up benchmarking now. Your 2026 data (due June 30, 2027) and prior years feed the tune-up and any high-performance claim.
- Decide on a pathway by early 2027. If you may qualify as high performance, the City lists April 5, 2027 as the due date for those reports.
- Line up a qualified specialist. Check the City's approved list, compare scopes and schedule site visits before the busy summer months.
- Budget for corrective work. Most fixes are operational (schedules, setpoints, controls), but plan for contractor time and staff availability.
- Use the findings. A tune-up report is a ready-made list of efficiency opportunities that can feed a capital plan, an emissions baseline or a funding application.
Turning compliance into a plan
Benchmarking and tune-ups are often treated as paperwork, but the data they produce answers real questions: where energy money is going, which systems drift out of tune, and which upgrades are worth funding. The same numbers support greenhouse gas reporting for sustainability and ESG goals and help frame energy resilience and efficiency projects. For owners juggling several buildings, a simple tracker of deadlines, data owners and contractors, run like any other managed program, keeps the work on schedule.
Questions about the rules themselves are best sent to the City at TuneUps@phila.gov or benchmarkinghelp@phila.gov. If you would like help organizing your data, planning the work around these deadlines or connecting the results to a broader energy strategy, get in touch with Pinnacle Strategy Group.
Benchmarking and tune-ups produce the data that shows where energy money goes and which upgrades are worth funding.