Many building owners think they’re ready, but Q2 audits often reveal hidden issues.
With just weeks left until the Q2 2025 deadline, the pressure is on for property owners to meet Washington State energy audit requirements under the Clean Buildings Performance Standard (CBPS). The Washington Clean Buildings Law 2025 demands strict energy reporting, documentation, and performance benchmarks, and missing the mark could mean fines of up to $5,000 per day. Even properties that appear compliant can stumble over details like outdated Energy Use Intensity (EUI) data or incomplete records. For commercial and multifamily building owners, ensuring CBPS compliance now is the only way to avoid penalties and last-minute surprises.
This guide lays out the final steps for a successful Q2 Washington State energy audit. Designed for property managers, sustainability coordinators, and facility directors, we’ll explain how to comply with Washington’s Clean Buildings Law in 2025, clarify CBPS Tier 1 and Tier 2 deadlines, and provide tools to help you meet your Washington State building energy performance goals. From audit prep to expert consulting, now is the time to act. Let’s make sure your building is truly ready, because the deadline is near, but with the right prep, you’ve still got time to succeed.
Clarifying Compliance: What CBPS Actually Requires in 2025
The Washington Clean Buildings Law 2025 was enacted to reduce greenhouse gas emissions from the state’s largest sources—commercial and multifamily buildings. The law’s key enforcement mechanism is the Clean Buildings Performance Standard (CBPS), which mandates that property owners report and meet specific energy performance thresholds. To comply, buildings must follow a strict set of requirements that go far beyond energy-efficient upgrades.
At the core of CBPS compliance is a verified Energy Use Intensity (EUI) score, benchmarked using the ENERGY STAR Portfolio Manager. EUI is a metric that expresses a building’s energy consumption relative to its size and use type (e.g., kBtu per square foot per year). Each property type is held to a unique EUI target, based on historical data, climate zone, and expected occupancy patterns.
To comply with CBPS by the Q2 2025 deadline, Tier 1 building owners (50,000+ sq. ft.) must:
- Submit accurate and up-to-date benchmarking data through ENERGY STAR Portfolio Manager
- Demonstrate an EUI at or below the state-mandated performance target
- Develop and maintain an Operations & Maintenance (O&M) Program tailored to their facility
- Prepare a detailed Energy Management Plan (EMP) covering reduction strategies and accountability
- Ensure that all staff involved in energy and facilities management receive proper training and record this training
- Upload all required documentation through the Washington State Clean Buildings Portal
For Tier 2 buildings (20,000–49,999 sq. ft.), these same requirements will apply, but with staggered deadlines extending beyond Q2 2025. However, starting compliance preparations now will prevent a last-minute scramble in future cycles.
Why Seemingly “Compliant” Buildings Are Failing Audits
Many property owners believe their buildings are already compliant because they’ve made energy upgrades, installed smart controls, or even earned ENERGY STAR certification in the past. However, compliance is not determined by perceived energy efficiency—it’s based on documentation and meeting CBPS-specific criteria. As audits have shown, even well-maintained buildings can fall short when scrutinized.
Here are the most common reasons compliant-seeming properties are flagged or fail CBPS audits:
Outdated or Inaccurate Benchmarking Data
Benchmarking data must cover the most recent 12 consecutive months and include all fuel types, electricity, gas, steam, etc. Any gap in utility records, incorrect square footage, or failure to include all energy meters can skew the EUI calculation and invalidate a submission.
Unverified or Incomplete Documentation
CBPS requires standardized reporting. This includes structured documentation of O&M activities, employee training logs, and evidence of retrofits or adjustments made to improve performance. Many owners submit informal notes, outdated checklists, or incomplete reports, which do not meet audit standards.
Weak or Incomplete Energy Management Plans
A CBPS-compliant EMP must outline how a building plans to reduce energy use, who is responsible for implementing changes, and how progress is tracked over time. Vague plans that lack timelines, defined goals, or tracking mechanisms are commonly rejected during audit reviews.
EUI Performance Above Target Thresholds
Even if a building is relatively energy-efficient, high occupancy rates, increased equipment loads, or operational schedule changes can drive EUI above acceptable limits. In many cases, buildings miss their target by a small margin due to incorrect assumptions about occupancy schedules or space usage.
These issues underscore the importance of proactive preparation and detailed verification, not just intent or past performance.
Step-by-Step: Preparing for a Successful Q2 Audit
With the Q2 2025 deadline looming, it’s critical to follow a structured approach. Many buildings will be racing to submit in the same quarter, so system backlogs, technical errors, or incomplete submissions could trigger enforcement actions even for owners who believe they’re compliant.
Below is a comprehensive checklist to prepare your building for a successful CBPS audit:
1. Reconfirm ENERGY STAR Portfolio Manager Data
- Review all property details, including gross square footage, number of floors, space type designation, and occupancy hours.
- Validate that every active energy meter is included, and check that fuel types and usage figures align with utility invoices.
- Make sure there are no data gaps in the 12-month period leading up to the submission deadline.
2. Benchmark Against Washington’s EUI Targets
- Download the latest EUI performance target tables from the Washington State Department of Commerce website.
- Identify the specific target for your building type and climate zone.
- Compare this benchmark to your current EUI—calculate the margin of safety or determine how much reduction is needed.
3. Update and Formalize Your Energy Management Plan
- Begin with a baseline EUI and identify key drivers of energy use (lighting, HVAC, plug loads, etc.).
- Document reduction strategies, such as retro-commissioning, equipment upgrades, or behavioral interventions.
- Assign responsibilities to key staff and set dates for performance evaluations and progress reports.
- Use the CBPS EMP template to ensure your plan includes all required elements.
4. Create a Fully Documented O&M Program
- Outline your preventive maintenance protocols, repair schedules, and vendor relationships.
- Include a log of service calls, filter changes, system calibrations, and inspections from the past year.
- Ensure the program aligns with current equipment specs and CBPS-mandated procedures.
5. Organize All Records for Submission
- Compile a centralized digital archive containing:
- ENERGY STAR benchmarking reports
- O&M documentation
- Training records and sign-in sheets
- Energy management plans
- Utility bills and invoices for efficiency upgrades
- Double-check each file for accuracy, proper formatting, and CBPS compatibility.
Avoiding Penalties: Final Quality Control Before Submission
The financial consequences of non-compliance are significant: up to $5,000 per day per building. Even minor errors—such as uploading the wrong file version or skipping one required document—can result in your submission being rejected, which triggers penalties until the issue is resolved.
Before you submit, complete a final review process:
- Have a facility director or sustainability coordinator perform a full audit dry run
- Check EUI results and ensure they fall within allowable thresholds
- Review all supporting documents for accuracy, signatures, and date stamps
- Confirm that your ENERGY STAR data matches utility invoices
- Log into the Clean Buildings Portal to verify access and understand the upload process
- Where possible, schedule a mock audit or pre-submission review with a qualified CBPS consultant
This quality control step can be the difference between seamless approval and a costly enforcement process.
Leveraging Expert Support Before the Deadline
Many building owners don’t realize how complex CBPS compliance can be until they begin preparing for an audit. Fortunately, professional support services are available to ease the burden. These experts offer tailored solutions that fit the unique needs of commercial and multifamily properties.
Types of support include:
- Portfolio-wide audits to identify high-risk properties
- EUI reduction strategies with data-backed recommendations
- Retro-commissioning services to improve HVAC efficiency and system controls
- CBPS documentation preparation, including templated reports and evidence archiving
- Staff training modules to ensure internal teams understand compliance responsibilities
While there’s a cost to hiring a CBPS expert, the investment typically pays off by avoiding potential penalties, last-minute rework, and rejected submissions. Additionally, many of these firms are familiar with Washington State’s enforcement patterns and can flag issues before they escalate.
Your Next Move Toward Compliance
Time is running out. As the Q2 2025 deadline approaches, building owners and managers across Washington State must shift from preparation to execution. This guide walked you through the final steps—from verifying ENERGY STAR data to crafting airtight Energy Management Plans and organizing full documentation. Even energy-efficient buildings risk failure if their documentation is incomplete. Don’t let small mistakes trigger big penalties. Now’s the moment to act with confidence, not hesitation.
Don’t let last-minute errors or overlooked details put your property at risk. Ensure compliance—schedule your Washington State energy audit today. Whether you need a second set of eyes, help interpreting EUI targets, or a full documentation review, our experts are here to guide you. Avoid costly penalties and gain peace of mind by locking in support now. Ready to move forward? Contact our team today to secure your Q2 submission.
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