Key takeaways
- The Department published the 2026 Covered Buildings List for Local Law 97 on March 23, 2026. It assigns every covered building a compliance path.
- A building's path can change between lists — because a dispute was approved, because another agency updated its data, or because something about the building changed.
- The path decides when the first report is due, so a change of path is a change of deadline. Buildings whose path changed without a dispute are flagged in the portal.
- If the data is wrong, the owner files a dispute in BEAM and, until it is resolved, keeps reporting exactly as before.
In this article
Local Law 97 is usually discussed as a question of emissions and fines. Before any of that, it is a question of a list: whether your building is on it, and which path it was given. The path is what sets the clock, and the clock moved for some buildings this year.
What the list is
The Department set it out in a service notice of March 30, 2026: 2026 Covered Buildings List for Local Law 97. The list itself was published a week earlier, on March 23.
Each building on it carries a compliance path:
| Path | What it means |
|---|---|
| CP0 | Article 320, beginning 2024 |
| CP1 | Article 320, beginning 2026 |
| CP2 | Article 320, beginning 2035 |
| CP3 | Article 321, beginning 2024 |
| CP4 | City building or NYCHA |
The two articles behind those codes are Article 320 and Article 321 of the Administrative Code, which is all the notice cites.
Why a path changes
A building can sit on a different path this year than last for three reasons the Department names: a dispute that was approved, updated data from a partner agency, or a change in the building's circumstances.
None of those three arrive as a letter. They appear on the list, which is why the list is worth opening once a year even when nothing about the building has changed in the owner's own records.
In the reporting portal, buildings whose path changed without a dispute are marked. The Department says they show New CBL CP in the covered status column.
What to do if the data is wrong
The owner is responsible for telling the Department when the data is wrong. The route is a CBL Dispute, filed as Ticket #1 in the reporting portal.
The Department's instruction while a dispute is open is important and easy to get backwards: keep reporting as you did before. A dispute is not a pause button. Disputes that are resolved after the list is published show up in the portal when they are decided.
The notice also gives a set of outcomes for buildings whose path moved, and the thread running through them is that the next report lands in 2027 rather than being retroactively owed:
- A move between CP0 and CP1 without a dispute: the next report is due in 2027, even where the 2026 path is CP0.
- A move from CP2, CP3 or CP4 in 2025 to CP0 or CP1 in 2026: the next report is due in 2027, and the owner may ask for a mediated resolution that year.
- A move to CP3 in 2026: the report is due in 2027, with the same option of mediation.
- A campus filing disturbed by a 2026 path change: every building in the campus gets a 2027 due date, and may seek mediation.
Where an owner simply agrees with an update and files no dispute, the compliance report is due in the first year after the calendar year in which the new path was published.
The practical reading
For an owner or a managing agent, the whole of this comes down to three habits.
Open the list every year. Not because your building changed, but because someone else's data about your building might have.
Treat a path change as a deadline change. The path is not a label; it is the year your reporting starts.
File the dispute early and keep reporting. The two are not alternatives. An unresolved dispute does not excuse a missed filing, and the Department's own instruction is to continue as before until it is decided.
The rest of the year's deadlines are in the 2026 sustainability calendar, and new construction has its own code question in 2020 or 2025 energy code.
Frequently asked questions
How do I know whether my building's path changed?
Check it in the reporting portal. Buildings whose path changed without a dispute carry a New CBL CP marker in the covered status column.
Does filing a dispute pause my reporting obligation?
No. The Department's instruction is to keep reporting as previously until the dispute is resolved.
My path changed from CP1 to CP0. Do I owe a report for an earlier year?
The notice describes the next report as due in 2027 for a move between CP0 and CP1 without a dispute, rather than retroactively. Confirm your building's position in the portal, since the outcome depends on which paths it moved between.
What if my building is not on the list at all?
Then it is not identified as covered for that filing year. If you believe that is wrong, or that it should not be there, the dispute route is the same.
Where can I read the notice?
It is on the Department's service updates page, and the link is in the first section of this article.
Conclusion
The Covered Buildings List is the quietest document in the Local Law 97 file and the one that sets everything else in motion. It takes ten minutes a year to check, the dispute route exists and is used, and the only genuinely expensive mistake is assuming last year's path is still yours.
Written by the engineers and laboratory technicians of Metric Consulting and Inspection, a Class 1 special inspection agency with a DOB-licensed concrete testing laboratory in Hicksville, New York, serving NYC construction since 2003.