Washington, D.C. BEPS Deadlines: Q2 Compliance Checklist To Avoid $10/Sq Ft Fines

Get Compliant To Avoid Costly Fines 

If you’re planning to wait until the end of 2025 to deal with Washington, D.C.’s Building Energy Performance Standards (BEPS), you’re already putting your property at risk, specifically, a $10 per square foot penalty for noncompliance. 

For commercial property owners and facility managers, Q2 of 2025 is the most critical window to ensure you’re on track. With over 3,000 buildings in D.C. subject to BEPS Phase 2, the city’s enforcement timeline is already in motion. If you haven’t completed your energy audit, chosen your compliance pathway, or submitted required documentation, now is the time to act. 

This article outlines the exact steps you need to take in Q2 to stay compliant and avoid costly fines, and how a free consultation with VertPro® can help simplify the process.

Why Q2 Is Pivotal For BEPS Compliance

D.C.’s BEPS program mandates that buildings over 25,000 square feet meet minimum energy performance standards, or take corrective action. The Phase 2 performance period is underway, and key milestones must be completed by midyear. 

Q2 is especially important because it’s the final opportunity to make proactive decisions, such as selecting the most cost-effective compliance pathway, completing required audits, and uploading critical documentation. Many property owners mistakenly assume year-end deadlines apply, but several key submissions are due by June 30. Missing them puts your building into automatic noncompliance, resulting in limited options and significant financial risk.

Your Q2 BEPS Compliance Checklist

To stay ahead of penalties, you need to complete the following core actions during Q2: 

Step 1: Confirm Your BEPS Status

Every building over 25,000 square feet in Washington, D.C. should have received a BEPS Phase 2 notice. If you’re not sure of your status, log into the DOEE Benchmarking Portal to confirm your building’s ENERGY STAR score or baseline performance data. If you don’t have access to this information, reach out to our team at VertPro.com for help gathering and verifying it. Confirming your eligibility and compliance requirements is a foundational step. Buildings that don’t verify their status by the end of Q2 face delayed action and potential noncompliance notices. 

Step 2: Choose And Submit Your BEPS Compliance Pathway

D.C. offers four compliance pathway options: the Standard Target Pathway, where buildings must meet a set performance score by the end of the cycle; the Performance Improvement Pathway, which requires a percentage-based reduction in site energy usage; the Prescriptive Pathway, which mandates a list of pre-approved efficiency upgrades; and the Alternative Compliance Pathway, designed for properties with special constraints such as limited capital or unique operational conditions. 

Selecting the right pathway depends on your building’s current performance, system age, and operational budget. If no selection is made by June 30, your building may be assigned a default pathway, often without regard to your specific needs or costs. Choosing proactively gives you the flexibility to control your timeline and expenses.

Schedule Your Energy Audit Now

A professional ASHRAE Level II energy audit is a cornerstone requirement for many BEPS compliance pathways. It must be conducted by a licensed energy professional and submitted to the Department of Energy and Environment within 60 days of completion. This audit provides the baseline performance data needed to prove compliance, or to support an improvement plan. 

If you delay scheduling your audit into Q3, you run the risk of limited availability from auditors and tight turnaround times for documentation. In addition, DOEE submission backlogs in Q4 may further complicate processing. The earlier you schedule, the more time you’ll have to interpret the results and align your upgrades with your compliance plan.

Upload Your Reporting Documents Before The Q2 Deadline

Once your audit and pathway decision are complete, you must upload several documents to the DOEE portal. These include your updated ENERGY STAR Portfolio Manager data, completed pathway selection forms, and the energy audit report. 

It’s important to note that simply working on upgrades or having improvements in progress does not exempt you from documentation deadlines. The city requires all supporting materials to be uploaded to their portal in order for a building to be officially marked as “in compliance.” Failure to do so by the Q2 cut-off could trigger automatic penalties, even if your building is actively working toward efficiency improvements. 

Plan And Budget For Energy Upgrades

While much of the BEPS process is about documentation, the ultimate goal is improved building performance. If you’re pursuing the Performance or Prescriptive Pathway, it’s essential to identify and begin planning your upgrades now. 

Start by reviewing your audit findings to determine which improvements offer the best return on investment. Common targets include HVAC replacements, LED lighting retrofits, or the installation of energy management systems. During Q2, it’s wise to secure contractor bids, explore incentive programs, and apply for rebates or financing options. Proactive planning helps reduce capital expenditure and avoids the inflated costs that come with last-minute compliance efforts. Waiting until the final months of 2025 will likely lead to higher labor costs and limited contractor availability.

Avoiding The $10/Sq Ft Fine: Why Time Matters

The most important takeaway? The $10 per square foot penalty is not hypothetical, it’s a real, enforceable consequence that applies to buildings that fail to meet BEPS requirements. For a 100,000 sq ft commercial property, that’s a potential $1 million fine. The penalty scales with building size, and for larger portfolios, the costs can become astronomical. 

However, every one of these penalties is preventable, if you take action this quarter. By confirming your status, selecting a compliance pathway, completing your audit, and uploading required documentation before the Q2 deadline, you avoid default assignments and demonstrate good-faith compliance efforts. 

Get Help From Local BEPS Experts

Washington, D.C.’s BEPS rules are complex and evolving, but you don’t have to figure them out alone. VertPro® specializes in guiding commercial building owners through BEPS compliance, from initial energy audits to full upgrade implementation. 

We provide:

  • BEPS Phase 2 status checks and compliance strategy 
  • ASHRAE Level II energy audits with fast turnaround 
  • Guidance on selecting the right compliance pathway 
  • Support with DOEE documentation and deadlines 
  • Contractor connections and upgrade planning assistance 

Our platform supports compliance with over 60 benchmarking and performance laws nationwide, making us a trusted partner for property managers, facility engineers, and ownership groups across the country.

Act Now Before Q2 Slips Away

The path to BEPS compliance isn’t just about avoiding fines, it’s about improving your property’s energy efficiency, reducing long-term operating costs, and enhancing asset value. The sooner you take action, the more options you have and the less you’ll spend to stay compliant. 

👉 Contact us for a free consultation with our D.C.-based compliance team today. We’ll review your status, recommend the right pathway, and build a custom plan to avoid penalties. 

👉 Visit VertPro.com to get instant audit pricing, download BEPS resources, and explore energy-saving solutions. 

The Q2 window is closing fast. Let us help you secure compliance, and peace of mind, before it’s too late.

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