Skip to main content
Local Law 88 · Article 311

Tenant Submetering in NYC: Who Needs It, and Why.

LL88's second half carries the same $1,500-a-year reporting penalty as the lighting. Who needs submeters, what the statements require, and what drives cost.

What the Law Asks For

In a covered building, generally 25,000 sq ft and up, a covered tenant space is either of these:

  • A single tenant over 5,000 sq ft. One tenant space larger than 5,000 gross square feet, on one or more floors, let to the same person.
  • A shared floor over 5,000 sq ft. A floor larger than 5,000 gross square feet made up of tenant spaces let to two or more different tenants.

Either trigger creates the obligation, in commercial and residential buildings alike, with dwelling units excepted per DOB's FAQ. Spaces already on a dedicated meter are excepted from new submeters, but not from the filing. In practice, multifamily buildings often need little physical work; offices with large tenants and shared floors are where metering work concentrates.

The requirement is measurement plus monthly statements showing each covered space's consumption (Administrative Code 28-311.4). Usage-based billing is not required; flat-rate arrangements can continue where the lease allows. On shared floors, one floor-level meter can serve multiple tenants when statements break down each share. The report carries the attestation, a list of covered spaces, and a sample statement, filed through BEAM.

What Drives the Cost

Cost varies building to building. What moves it:

  • How many covered spaces. The trigger count sets the meter count.
  • Floor-level vs. per-tenant metering. One floor meter with allocated statements often serves a shared floor.
  • Panel and riser access. Where the panels live drives the labor.
  • What already exists. Existing dedicated meters can reduce the job to an attestation.

The cost of doing nothing is fixed: $1,500 a year for the missing report, plus $500 a year per unmetered covered space. A registered design professional or licensed electrician certifies and files. The extension and missed-deadline guide covers the penalty picture, and the full law page covers the lighting half.

Does LL88 submetering apply to residential buildings?
Per DOB's FAQ, the covered-tenant-space rules apply to both commercial and residential buildings, with individual dwelling units excepted. In practice a residential building's obligation usually comes from commercial tenants, amenity spaces, or shared floors over 5,000 square feet rather than the apartments.
Our tenant spaces already have their own Con Ed meters. Are we done?
Close, but the report is still owed. Dedicated meters satisfy the submeter requirement, and DOB confirms a submission is required even where meters are already in place. A qualified professional attests to the existing metering and files it.
Do I have to bill tenants based on the submeter readings?
No. The law requires measurement and monthly statements showing consumption. Whether electricity is billed flat-rate or by usage stays a lease question. Many owners use the rollout to revisit utility clauses, but that is a choice rather than a requirement.
How much does submetering cost?
There isn't a reliable flat number; it depends on the covered-space count, floor-level vs. per-tenant metering, panel access, and what already exists. What is fixed, per DOB rule: $1,500 a year for the missing report, plus $500 a year per unmetered covered space. A survey scopes the drivers before anything is committed.
Both halves, one pass

Submetering Is Half of LL88. We Close Both.

The survey maps your covered tenant spaces and existing metering, and the certified filing closes lighting and submetering together. No obligation; we respond within one business day.

200+ ll88 filings completed · 1,500+ buildings surveyed

We typically respond within one business day.

By submitting, you agree to our Privacy Policy. We'll only use your information to respond to your inquiry.

Penalty figures and compliance details reflect DOB's published rules and can change. This page is general information, not legal or financial advice; confirm specifics with DOB, your utility, and your own professionals.

Last updated: July 2026. NYC building compliance rules, deadlines, and DOB procedures may change.