Q2 is the most dangerous quarter for San Francisco building owners, and most don’t realize it until the fines arrive. While enforcement may seem inconsistent year-round, Q2 brings sharp focus from the San Francisco Department of the Environment, especially around Ordinance 116-13 (Existing Commercial Buildings Energy Performance Ordinance) and Ordinance 009-21 (Energy Performance Targets). These ordinances trigger mid-year reporting requirements that can’t be pushed off. Older buildings and high-usage properties face even tighter scrutiny, as their performance data often flags them for audits or notices of violation. One of the most common mistakes? Assuming a prior-year report covers your current Q2 obligation, when in fact, updated benchmarking must reflect the latest 12-month data.
Even those generally familiar with energy compliance may not realize Q2 is when enforcement heats up, alongside the city’s push to meet new carbon reduction benchmarks. With deadlines for energy reports, tune-ups, and performance disclosures often falling between April and June, it’s critical to have your documentation and strategy in place. This blog will guide you through the specific 2025 Q2 requirements, help you identify whether your building is at higher risk, and explain how Benchmarking services can protect your bottom line. If you want to avoid steep fines and surprise audits, now is the time to act.
Key Ordinances Driving Q2 Enforcement
These ordinances apply to all non-residential buildings over 10,000 sq. ft., and many over 50,000 sq. ft. have even stricter performance expectations.
Ordinance 116-13: Benchmarking and Disclosure
Ordinance 116-13 mandates that all commercial buildings over 10,000 square feet in San Francisco annually benchmark and disclose their energy usage. While many property owners complete this task each year, Q2 is when the city intensifies enforcement, reviewing current reports for accuracy and completeness.
For Q2 2025, ensure the following:
- Your ENERGY STAR Portfolio Manager account includes updated 12-month data through at least March 2025.
- You’ve authorized the City of San Francisco to access your benchmarking records.
- Corrections or resubmissions from prior years are resolved before the May deadline.
Outdated or partial data is a common reason for penalties. Benchmarking reports that don’t reflect the most recent full 12-month period are flagged, even if submitted on time.
Ordinance 009-21: Performance Targets and Carbon Reduction
Unlike Ordinance 116-13, which focuses on reporting, Ordinance 009-21 requires ongoing improvement in energy performance. In 2025, many buildings hit new compliance phases tied to building emissions and tune-up schedules.
Check if your property requires:
- A Building Emissions Reduction Plan.
- Tune-up documentation to confirm efficiency upgrades.
- Performance goals tailored to your building type and energy usage.
Buildings showing little or no improvement from past reports may be selected for audits in Q2. Many property owners mistakenly assume that basic compliance with Ordinance 116-13 satisfies 009-21 requirements—it does not.
Q2 2025 Compliance Checklist
Use this timeline to ensure you meet all mid-year compliance obligations and avoid penalties.
✅ By April 15
• Update ENERGY STAR Portfolio Manager with complete 2024 data.
• Review prior reports for errors or gaps.
✅ By May 1
• Submit Benchmarking reports for buildings over 50,000 sq. ft.
• Confirm disclosure documents for Ordinance 009-21 are submitted.
• Authorize City of San Francisco access to your energy data.
✅ By June 1
• Complete any required building tune-ups.
• Submit tune-up confirmation or performance plan documentation.
✅ By June 15
• Final corrections due for all Benchmarking and performance data.
• Prepare for audit selection or data requests from city agencies.
Missing these deadlines can result in cumulative daily penalties and city notices, especially during the Q2 enforcement window.
Common Pitfalls That Lead to Penalties
Mistaking Benchmarking for Full Compliance
A frequent mistake is assuming Benchmarking alone meets all requirements. In Q2, San Francisco reviews both your data and actual building performance.
Common issues include:
- Relying on outdated or incomplete ENERGY STAR data.
- Missing additional tune-up or disclosure requirements under Ordinance 009-21.
- Failing to update records with tenant-level energy use data.
Delaying Tune-Ups and Retrofits
Tune-ups are not optional for underperforming buildings. Those that missed improvement milestones in 2024 may face inspections in Q2 2025.
High-risk properties often include:
- Commercial buildings built before 1980 with no documented upgrades.
- Hotels and retail locations with inconsistent energy profiles.
- Multi-tenant properties lacking full data access or verification.
Failure to address these risks by Q2 can escalate into formal violation notices or audit demands.
How to Assess Your Building’s Q2 Risk Level
Building Age, Size, and Energy Profile
San Francisco enforcement is increasingly data-driven. Certain factors significantly increase your risk of being audited in Q2.
You may be flagged if:
- Your building is over 50,000 sq. ft. and has a high energy use intensity (EUI).
- Benchmarking reports contain gaps or anomalies in tenant data.
- Your 2024 submission was late, inaccurate, or missing altogether.
Receiving a warning email is often the last step before penalties are applied.
Why Q2 Deadlines Can’t Be Ignored
Penalties Increase Rapidly After Deadlines
San Francisco applies daily fines for non-compliance. Even missing a deadline by a week can result in thousands of dollars in penalties, especially for owners with multiple properties.
Critical Q2 compliance dates include:
- May 1 – Benchmarking report deadline.
- June 1 – Tune-up and disclosure submissions.
- June 15 – Final correction window.
City enforcement becomes less forgiving as Q2 progresses. Reports not submitted or corrected by June 15 are automatically marked as violations.
The City Focuses Enforcement in Q2
While Q1 is typically reserved for outreach, Q2 is when the city begins active enforcement. They cross-check energy reports, analyze data anomalies, and initiate fines.
Expect increased attention if your building had previous compliance issues or if your data profile appears inconsistent.
How Benchmarking Services Can Help
Accuracy, Strategy, and Risk Mitigation
Professional Benchmarking providers do more than fill out forms—they align your reporting with both regulatory deadlines and building-specific requirements.
Benchmarking services include:
- Setup and maintenance of your ENERGY STAR Portfolio Manager account.
- Detailed analysis of energy use and carbon intensity.
- Timely submission of Benchmarking and performance documents.
- Alerts for missing tenant data or pending deadlines.
They also act as your liaison with city departments if errors or audits arise.
Access to Rebate and Incentive Programs
Beyond compliance, early reporting and improvement can unlock funding opportunities that offset upgrade costs.
Notable programs include:
- BayREN Commercial Rebates
Financial incentives for HVAC retrofits, lighting upgrades, and more.
Explore Rebates → - GoGreen Energy Efficiency Financing
Low-interest financing for qualifying commercial upgrades.
Visit Site → - San Francisco Environment Incentives
Performance-based rebates tied to Ordinance 009-21 improvements.
Learn More →
Many of these programs require proactive compliance. A qualified Benchmarking partner can identify which rebates apply and assist in application submissions.
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Stay Ahead of San Francisco’s Q2 Fines
San Francisco’s Q2 compliance period isn’t just another checkpoint—it’s when the city gets serious. Between Ordinance 116-13 and 009-21, property owners face strict mid-year requirements that can’t be pushed off or ignored. We’ve walked through the most common mistakes, key deadlines, and risk factors that trigger audits, fines, and notices of violation. If your building is over 10,000 square feet, shows little energy improvement, or missed last year’s benchmarks, you’re already on the city’s radar. Acting now can prevent the scramble—and the penalties—that often hit in May and June.
Partnering with a Benchmarking service is the easiest way to stay ahead. We ensure your reporting is accurate, timely, and aligned with both ordinances. You’ll meet all deadlines, avoid common compliance traps, and even unlock rebates to cover upgrade costs. Don’t let Q2 pass you by while fines add up. Get your building compliant today—and protect your bottom line before the city comes calling.
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