Phase 1
Best Practice: Before July 1, 2026
The Operational Start
The legal Tier 2 reporting deadline is July 1, 2027. The standard also requires at least 12 consecutive months of measured energy data for the compliance calculation.
01Timeline
The Tier 2 timeline is straightforward once the three main milestones are visible.
The legal deadline is July 1, 2027, but the practical work often starts earlier if the building does not already have a clean 12-month energy-data record.
Compliance Timeline
These are the only stages most owners need to understand at the start.
Best practice is to have the O&M program, the energy management plan, and the tracking setup underway early enough to avoid a compressed filing period in 2027.
Phase 2
July 2026 – June 2027
The Tracking Period
The standard requires at least 12 consecutive months of measured energy-use data, and the building owner must benchmark the property and calculate the applicable energy target as part of the Tier 2 compliance package.
02Phase 3
July 1, 2027
The Hard Deadline
By July 1, 2027, Tier 2 owners must submit compliance reports to Commerce. By that date, the owner must have benchmarking complete, an operations and maintenance program fully implemented, and an energy management plan in place.
03After the initial filing, the state requires continued compliance reporting on a five-year cycle. The immediate question for most owners is simply whether the building has enough time to get the first package done correctly.
Next
Once the timeline is clear, the next question is whether the building is ready.
A building review is the fastest way to confirm the likely path, missing workstreams, and whether the timeline is already tight.