DC's BEPS Deadline Is Here. Is Your Building Ready?
AppWork | COMPLIANCE INSIGHT | May 2025
WASHINGTON DC · BUILDING ENERGY UPDATE
DC's BEPS Deadline Is Here. Is Your Building Ready?
Washington DC's Building Energy Performance Standards are no longer on the horizon. The first compliance cycle ends December 31, 2026. DOEE begins assessing penalties in 2027. For multifamily operators in DC, the window is closing.
66
Minimum ENERGY STAR score required for multifamily buildings in Cycle 1
$10
Per square foot penalty for noncompliance, assessed starting 2027
70%+
Of DC's citywide greenhouse gas emissions come from buildings
What BEPS Actually Is
BEPS was established by the Clean Energy DC Omnibus Amendment Act of 2018 with one clear goal: reduce greenhouse gas emissions and energy consumption in DC buildings by 50% by 2032. Buildings account for more than 70% of citywide emissions, so the District isn't leaving it up to voluntary action.
Unlike benchmarking programs that only require reporting, BEPS demands actual improvement. The program sets a minimum energy performance threshold by property type, measured against the local median ENERGY STAR score. Buildings that fall below their threshold don't just get a warning. They enter a compliance cycle with a hard deadline to demonstrate measurable progress, or face penalties designed to make non-compliance more expensive than fixing the problem.
Buildings account for more than 70% of DC's citywide emissions. BEPS isn't a disclosure program. It's a performance mandate.
For multifamily buildings, the Cycle 1 BEPS standard is an ENERGY STAR score of 66 or higher. If your building scored below that threshold, you've been in an active compliance cycle since January 1, 2021, with until December 31, 2026 to demonstrate improvement.
HOW BEPS ROLLS OUT OVER TIME
C1 — Cycle 1: 2021 to 2026 — NOW Privately-owned buildings 50,000+ sq ft and DC-owned buildings 10,000+ sq ft. Compliance ends December 31, 2026. DOEE reviews 2026 benchmarking data and assesses penalties starting April 2027.
C2 — Cycle 2: 2027 to 2032 Expands to all privately-owned buildings 25,000+ sq ft. Second six-year compliance cycle begins January 1, 2027.
C3 — Cycle 3: 2033 onward All buildings 10,000+ sq ft brought into the program. Full deployment covers virtually every significant commercial and multifamily building in the District.
If your building is between 10,000 and 50,000 sq ft, your BEPS compliance clock hasn't started yet. But your benchmarking obligation is already underway. Buildings over 10,000 sq ft were required to submit 2025 data by May 1, 2026. If that deadline passed without a submission, getting your benchmarking in order should be an immediate priority, as that data becomes the foundation for your future BEPS cycle.
The Financial Stakes
The penalty structure was designed with a specific intent: make non-compliance more expensive than the cost of building improvements. DOEE has been explicit about its readiness to enforce, and the math is unforgiving for operators who do nothing.
| $10 PER SQ FT | Maximum penalty per square foot of gross floor area Capped at $7.5 million per property. For a 75,000 sq ft building making zero progress: $750,000 assessed in 2027. Penalties are proportional, so every point of improvement directly reduces exposure. But zero progress means full exposure. |
The proportional model is good news for operators who have been working their compliance pathway. A building on the Performance Pathway that achieves half of its required improvement sees roughly half the maximum fine. Progress counts. The operators most exposed are the ones who haven't started.
THE FOUR COMPLIANCE PATHWAYS
Buildings that don't meet the BEPS standard choose one of four routes. The right one depends on how far below the target your building sits and what capital you have available:
Standard Target
Meet or exceed an ENERGY STAR score of 66 for multifamily by end of cycle. Best for buildings close to the target.
Performance Pathway
Achieve a 20% reduction in site EUI from 2019 baseline. Most common for buildings significantly below target.
Prescriptive Pathway
Implement a defined set of cost-effective efficiency measures outlined in DOEE's Compliance Guidebook.
Alternative Compliance
Work directly with DOEE on a custom pathway for buildings with unique circumstances.
Key Dates and Numbers
$7.5M
Max penalty per property
Dec 31
2026 compliance deadline, Cycle 1
66
Min ENERGY STAR score for multifamily
Apr 1
2027 deadline for Completed Actions Report
Energy Compliance Is Also a Maintenance Problem
Here's the connection most operators miss: the path to a better ENERGY STAR score runs directly through your maintenance operations. HVAC systems not serviced on schedule, equipment running outside of spec, deferred repairs that quietly drain efficiency. These aren't just resident satisfaction issues. They're BEPS issues.
Building energy performance is a live, ongoing number. It doesn't improve because you filed a compliance pathway. It improves because the physical systems in your building are maintained, repaired, and upgraded consistently. For multifamily operators in DC, the quality of your maintenance program is now directly tied to your regulatory standing and financial exposure.
FOUR CHALLENGES OPERATORS FACE RIGHT NOW
01 — THE CHALLENGE: HVAC work orders sit open too long
Deferred HVAC repairs are one of the top drivers of poor energy performance. Every day an HVAC unit runs inefficiently affects your ENERGY STAR score, and most operators have no real-time visibility into how long jobs are sitting open.
HOW APPWORK HELPS: AppWork tracks every open work order with timestamps, priority status, and days elapsed. HVAC requests can be flagged for escalation before they become energy drains, not discovered during an annual audit.
02 — THE CHALLENGE: No documentation of completed improvements
DOEE requires a Completed Actions Report with verified 2026 benchmarking data by April 1, 2027. If your maintenance records live in a PMS module, a spreadsheet, or an email thread, assembling that documentation under pressure is a real risk.
HOW APPWORK HELPS: Every work order closed in AppWork captures completion notes, photos, and a timestamp. Records are organized, searchable, and audit-ready from the moment a tech closes the job, not assembled retroactively under deadline pressure.
03 — THE CHALLENGE: Portfolio operators can't see which buildings need attention most
For operators managing multiple DC properties, figuring out which buildings are furthest from compliance requires aggregating data from multiple systems, or just guessing. Neither works when penalties are calculated per square foot.
HOW APPWORK HELPS: AppWork's Insight Reports surface open items, completion trends, and anomalies across every property in your portfolio. Regional managers see where to focus without digging through individual site reports.
04 — THE CHALLENGE: Inconsistent technician adoption means incomplete records
If your techs are only logging 60% of work orders in your PMS, you don't have an accurate picture of what's been done. Compliance reviews depend on complete records, not best-effort ones.
HOW APPWORK HELPS: AppWork's Technician App is built for how maintenance staff actually work, with offline mode, mobile-first design, and a gamification layer that drives consistent usage. 99% adoption means complete records, not patchy ones.
How AppWork Supports BEPS Compliance
AppWork is a maintenance management platform built specifically for multifamily operators. It's not an energy monitoring tool. But the buildings that perform best on ENERGY STAR benchmarks are almost always the buildings with the tightest maintenance operations: systems get fixed before they fail, equipment runs the way it's supposed to, and repairs don't get deferred because nobody noticed the work order was open.
In a BEPS environment, that operational discipline has a direct dollar value attached to it.
APPWORK FEATURE SPOTLIGHT: Inspections Built for Compliance Documentation
AppWork's Inspections module captures condition documentation with photos tied to specific units, systems, and dates. Whether you're documenting HVAC upgrades, equipment replacements, or other capital improvements as part of your BEPS compliance pathway, every action is recorded and retrievable. The same infrastructure that handles AB 2801 compliance in California gives DC operators the audit trail DOEE requires for reporting.
When DOEE reviews your Completed Actions Report in April 2027, you'll need documentation of the improvements your building made during the compliance cycle. AppWork gives you a complete, timestamped record of every work order completed at every property, with photos and technician notes attached to each job. No scrambling. No reconstructing records from memory three months before the deadline.
Where DC Operators Should Focus Right Now
Cycle 1 compliance ends December 31, 2026. If you're in Cycle 1 and haven't been actively working your compliance pathway, the time to accelerate is now. Here's where to start:
- Pull your building's current ENERGY STAR score from Portfolio Manager and compare it to the multifamily target of 66. Know your gap before making any other decisions.
- Confirm which compliance pathway you've selected. If you haven't selected one, do it now. Each pathway has different documentation and verification requirements.
- Audit your open work orders with specific attention to HVAC and other energy-impacting systems, both of which have outsized impact on ENERGY STAR performance.
- Make sure your maintenance records are complete and exportable. DOEE will want a Completed Actions Report with verified 2026 benchmarking data by April 1, 2027.
- If you manage multiple DC properties, get portfolio-level visibility into which buildings are furthest from compliance so you can prioritize capital and staff resources accordingly.
- If you're under 50,000 sq ft and not yet in Cycle 1, the May 1, 2026 benchmarking deadline has passed. If you missed it, address it now. Your 2025 data is the foundation for your future BEPS cycle and late submission is better than none.
DC Operators Are Under Pressure. AppWork Is Built for It.
AppWork was built by people who have sat in the same seat you're in. Our CEO Sean Landsberg spent years running operations for a 12,000+ unit portfolio before building AppWork because the tools that existed weren't good enough. That's the lens through which every feature is designed: what does a property manager or regional VP actually need to run this well?
BEPS is the kind of regulation that separates operators with real maintenance infrastructure from those making do with whatever their PMS provides. The financial stakes are too high to run your DC portfolio on incomplete data. AppWork gives you the visibility, documentation, and operational consistency to meet compliance requirements without adding work to your team's plate.
And if you're watching DC from another market: you're right to pay attention. DC was the first mandatory building performance standard in the nation, but the model is spreading. New York's Local Law 97 is already in effect. Similar frameworks are being adopted across major metros. The operators building strong maintenance operations now are the ones who will be ready when it arrives.
66%
of work orders completed within 24 hours on AppWork
99%
technician adoption rate, so no job goes unlogged
100%
documented: every job closed with notes, photos and timestamp
GET STARTED — See How AppWork Supports Compliance
Get a look at how DC multifamily operators use AppWork to track work orders, document completions, and stay ahead of regulatory requirements.