Building Performance Standards are spreading fast
Buildings are among the largest sources of emissions in U.S. cities, and Building Performance Standards (BPS) have become one of the main tools governments use to cut them. Unlike benchmarking laws, which only require owners to report energy use, BPS set performance targets that existing buildings must meet, with fines for those that fall short.
Adoption of BPS has accelerated in recent years. As of May 2022, ten U.S. jurisdictions had adopted BPS policies. Today, 16 BPS policies have been enacted, while 49 state and local governments have committed to advancing BPS policies through the National BPS Coalition.
For owners and operators, that creates a moving target:
- More markets, different rules. NYC's Local Law 97 and Boston's BERDO 2.0 establish greenhouse gas (GHG) emissions limits for covered buildings, while Energize Denver sets site energy use intensity (EUI) targets. Each policy has its own applicability thresholds, compliance timelines, and penalties.
- Policies keep changing. Targets, deadlines and emission factors are revised regularly, and many jurisdictions have alternative compliance pathways beyond simply hitting a performance target.
- Legal challenges add uncertainty. A recent district court ruling found that parts of Colorado's statewide BPS may be preempted by federal law. The ruling applies to the site EUI metric, not greenhouse gas emissions, so owners still need to plan for compliance.
Staying current across a multi-market portfolio is now a full-time job. That's why Cambio has partnered with the Institute for Market Transformation (IMT), the nonprofit that has helped shape Building Performance Standards across the United States.
Through this partnership, the market-leading data from IMT and Cambio’s platform come together. For our customers, that means the regulatory data behind your compliance plans now comes from the organization that knows these policies best.
How Cambio helps you stay ahead of BPS
Compliance starts with complete data and ends with the right retrofits. Cambio covers the full path.
Regulation tracking, fine estimates and retrofit analytics
With IMT's monthly policy data feeding the platform, Cambio helps you:
- Track regulations across every jurisdiction in your portfolio, with updates to deadlines, targets and penalties reflected as policies change.
- Estimate fines based on each building's current and projected performance, so you can see your exposure by year and by market.
- Analyze retrofits against that exposure, ranking projects by payback, carbon impact and fines avoided.
Tenant data collection, handled by agents
Many BPS and benchmarking laws require whole-building energy data, including the tenant-metered spaces landlords don't control. Cambio's agentic workflows close those gaps for you. The platform monitors energy data across your portfolio and flags gaps before deadlines. Where utilities provide whole-building data, our Benchmarking Agent pre-fills and submits the request. Where tenant authorization is needed, an automated outreach engine contacts tenants, tracks responses and follows up until the data is in. Verified data then flows straight into ENERGY STAR Portfolio Manager.
Compliance pathways through AI-based retrofit project tracking
Knowing you're out of compliance is only useful if you know what to do about it. Cambio's AI-powered retrofit analytics review each building's energy audits, property condition assessments and performance data to recommend projects, which our in-house building engineers then review. Teams track every retrofit project in one place and see how each one moves a building toward its targets, so portfolio managers can compare compliance pathways and build capital plans that hold up.
Case study: a $400k retrofit plan that avoided ~$14M in fines
A $14B U.S. real estate owner rolled out Cambio across 98 office buildings totaling 29M+ square feet in 13 major markets. During onboarding, the platform flagged a risk no one had seen coming.
The challenge. One Denver office building was on track for roughly $14M in fines over its investment horizon under Energize Denver, the city's Building Performance Standard. On paper, the building looked well managed, with ENERGY STAR benchmarking and prior audits in place. Once Cambio modeled its actual performance against the law's thresholds and timeline, the compliance gap became clear.
The solution. Cambio's platform:
- Cross-checked the building's performance data against Energize Denver requirements
- Modeled when and how the asset would fall out of compliance
- Simulated thousands of retrofit combinations against fine timelines, ROI thresholds and tenant constraints
Instead of a costly deep retrofit, Cambio surfaced a focused plan of about $400K in targeted upgrades across HVAC optimization, controls, envelope and lighting. The owner began implementing the retrofits in Q4 2024.
The results.
Projected fines avoided ~$14M
Capital spend identified ~$400K
Return on compliance capex ~34:1 (~3,400% ROI)
The owner then applied the same workflow across their broader portfolio to map exposure to laws like NYC's Local Law 97 and Boston's BERDO 2.0. As one asset manager put it: "We initially saw our Denver fine mitigation as a one-off problem. It became our proof-of-concept for building a proactive compliance posture across the whole portfolio."
Turn BPS risk into a capital plan
Building Performance Standards aren't slowing down, and the cost of waiting grows every compliance cycle. With IMT's policy expertise behind our data, Cambio helps you see your exposure early, close data gaps automatically and invest in the retrofits that pay off.
Want to know where your portfolio stands? Book a demo and we'll show you your BPS exposure, projected fines and the retrofit pathways to avoid them.
