The LL97 Grace Period Ends June 30. After That, the Penalty Is Automatic.
There are two ways a building gets in trouble under Local Law 97. One is going over your carbon cap, which costs $268 for every metric ton of CO2 you emit above the limit. The other is simpler and easier to trip over: not filing your annual report at all.
That second deadline is about to bite. The LL97 report covering your building's 2025 energy use was due May 1, 2026. An automatic 60-day grace period runs to June 30, 2026. After that, the late penalties start, and unlike the carbon-cap math, this one does not care whether your building is efficient. It only cares whether you filed.
Two Different Penalties, Do Not Confuse Them
This trips up a lot of owners, so it is worth being precise. LL97 has two separate financial penalties, and you can owe one without owing the other.
- Exceeding your emissions cap: $268 per metric ton of CO2 equivalent over your annual limit. This is the one most coverage focuses on.
- Failing to file your report: a penalty of up to $0.50 per square foot, per month, for every month the report is late. A building can be comfortably under its carbon cap and still rack up this penalty simply by not submitting the paperwork.
At the top of that range, a 25,000-square-foot building is looking at as much as $12,500 a month, and a 100,000-square-foot building as much as $50,000 a month. It accrues for every month the report is outstanding. This is not a one-time fine.
What June 30 Actually Means
May 1 was the deadline, but DOB built in a 60-day grace period, so nothing bad happens if you file by June 30. June 30 is the real wall. Here is what happens on each side of it:
- File by June 30: no late penalty. You are on time as far as enforcement is concerned.
- Need more time: you can request an extension through the BEAM portal by June 30 for a $60 fee, which pushes your filing deadline to August 29, 2026. It is not automatic. You have to apply before June 30.
- Do nothing: the grace period is not a clean slate. If you have not filed by June 30, the late penalty applies and can be charged back to the original May 1 deadline, not just from July 1. And your building joins the list DOB is actively working through.
Enforcement Is Not Theoretical Anymore
For the first LL97 cycle, DOB has said the large majority of covered buildings filed (around 93 percent of private covered properties), which leaves roughly 1,400 that did not. Those are not being ignored. DOB is issuing Notices of Deficiency, giving owners an additional window to file, and preparing cases at the Office of Administrative Trials and Hearings (OATH) for the buildings that keep ignoring it.
In other words, the city moved past warnings. If your building is in that non-filing group, the question is not whether a penalty is coming. It is how many months of $0.50 per square foot you let stack up first.
"I Think We Filed" Is Not the Same as Filed
A surprising number of owners are not sure. Maybe a managing agent said they would handle it. Maybe a report was started in the BEAM portal but never submitted. Maybe last year's extension got mistaken for this year's filing. Prior-year extensions do not carry over, and a draft in the portal is not a filed report.
It takes ten minutes to confirm your building's status, and the downside of assuming wrong is $12,500 a month and up. If you are not certain, check before June 30, not after.
While You Are Looking at June 30
The filing deadline is not the only thing landing on June 30. Two tax breaks that help pay for the upgrades LL97 pushes you toward, the federal 179D deduction and NYC's J-51 abatement, hit their own hard cutoffs the same day. We covered those in a separate post on the June 30 tax deadlines. If you are already pulling your building's paperwork together, it is worth knowing both clocks are running at once.
What To Do This Week
- Confirm whether you actually filed. Not "we meant to." Verify the CY2025 report was submitted in BEAM, not just started.
- If you did not file, decide now: submit the report before June 30, or request the $60 extension to August 29. Either beats the penalty.
- Separate the filing problem from the cap problem. Filing on time stops the $0.50 penalty. It does not tell you whether you are over your carbon cap. Know both numbers.
- If you are over your cap, the same retrofits that fix that can be funded with rebates, abatements, and financing. Penalty avoided is only half the money on the table.
CompliantLens looks up your building, shows whether it is covered by LL97, estimates your carbon cap and potential penalty, and surfaces the incentives that offset the cost of getting compliant. It takes about a minute.
Sources: NYC Department of Buildings, Local Law 97 guidance and compliance reporting pages (nyc.gov/site/buildings/codes/ll97-greenhouse-gas-emissions-reductions.page); NYC DOB "User Guide: Local Law 97 Extension Requests" (extension_req.pdf), confirming the June 30 extension request deadline, $60 fee, and August 29, 2026 extended filing date; NYC DOB statements on first-cycle filing rates and enforcement against non-filers; NYC Administrative Code, Local Law 97 penalty provisions ($268/tCO2e over cap; up to $0.50/sq ft/month for failure to file). The May 1 deadline and 60-day grace period to June 30 are corroborated by NYC DOB and multiple NYC real estate and engineering advisories. This content is for informational purposes only and does not constitute legal, tax, or financial advice. Confirm your building's specific LL97 status and deadlines with NYC DOB and qualified professionals.