Missed the LL88 Deadline? Where Things Stand.

Dates and fees from DOB's published LL88 guidance, checked July 2026. DOB's service notices are the authoritative source for the current filing year.

Where Things Stand

Local Law 88 required covered buildings, generally those over 25,000 square feet, to bring lighting up to the energy code and submeter covered tenant spaces by January 1, 2025. Reports go through the city's BEAM portal. DOB has not published any further compliance extension.

The filing cycle does repeat. DOB republishes its covered buildings list each March, and buildings that haven't demonstrated compliance are expected to file again each year. The report is due May 1 with a grace period to June 30. Per DOB's published dates, buildings that also file LL97 in the same year can request an extension to December 31, and the request window closes August 29.

The penalties are set by DOB rule (Rule 103-18) and are assessed annually until each report is filed:

• $1,500 per year for a missing lighting upgrade report
• $1,500 per year for a missing submeter installation report
• $500 per year for each covered tenant space still without a required submeter, even after a report is filed (see the submetering guide)

A building missing both reports accrues $3,000 a year. The filing fee is $115, once.

Where Buildings Actually Are

The work is done, the filing isn't. DOB confirms a submission is required even where the work or the metering is already in place. A qualified professional documents the existing condition and files it. Often a quick close-out.

The fixtures went in, the controls never did. This is the case we run into most, and the most involved. LEDs were installed years ago, but the controls the code calls for were skipped, half-installed, or never commissioned. The filing needs the whole lighting system at code, and the controls are also where the remaining energy savings sit. That work is its own discipline; see NLC design & commissioning.

Little or nothing has been done. The path is the same as before the deadline: survey, upgrade plan, filing. It just runs against accruing penalties now. The four-question checklist is a quick way to place your building.

Done and filed. The obligation is closed. Owners in this spot usually come to us for the savings side instead: tuning or redesigning the controls to get more out of lighting that already complies.