Every other compliance obligation in this city is settled between an owner and an agency. The filing goes in, the violation comes or does not, and the public never sees it.
Local Law 33 is different. It posts your result on your own front door.
The requirement
Local Law 33 of 2018, as amended by Local Law 95 of 2019, requires buildings over 25,000 square feet to publicly display a Building Energy Efficiency Rating Label at the building entrance.
The cycle is annual and narrow:
- 1 October — new labels become available to owners.
- 31 October — the label must be downloaded and posted in the lobby.
Both dates fall in the same month, which is exactly why this gets missed. Owners who register 1 October as "the energy label date" frequently read it as a deadline rather than as the start of a one-month window.
Failure to display draws a DOB violation and a fine of $1,250 for applicable buildings.
Confirm the current threshold, dates and penalty with DOB before relying on this summary.
What the letters mean
The label carries a 1-to-100 ENERGY STAR score and a letter grade derived from it:
| Grade | ENERGY STAR score |
|---|---|
| A | 85 or above |
| B | 70 to under 85 |
| C | 55 to under 70 |
| D | Below 55 |
Two further letters appear on labels and neither is a performance grade:
- F — the building did not submit required benchmarking information.
- N — the building is exempt from benchmarking, or is not covered by the ENERGY STAR program.
Why an F is worse than a D
This distinction is the single most useful thing on this page.
A D means the building performs poorly. It is an honest result, it is common in older housing stock with original systems, and it is fixable over time with capital work.
An F means nobody filed the benchmarking data. It says nothing whatsoever about how the building performs — a well-run, efficient building that missed a filing gets an F, and a genuinely terrible building that filed honestly gets a D.
But the person reading the label at the front door does not know that. To a prospective tenant, an F reads as either the worst possible building or an owner who cannot be bothered — and to DOB it is a separate benchmarking compliance gap that still has to be closed.
So the counterintuitive priority for an owner sitting on an F is not an energy retrofit. It is a filing.
The grade is doing marketing, every day
Owners treat this as a compliance item and underweight the other half of it.
The label is at the entrance. Every prospective tenant walks past it on the way to a showing. So does every broker, every unit purchaser touring a co-op or condo, and every appraiser. No other obligation on a New York owner's calendar publishes its result where the customer stands.
That does not mean panic over a C. It does mean that when a building is planning capital work anyway — a boiler replacement, heating distribution, windows, controls — the energy grade is a real and measurable output of that spending, not just a side effect. A board debating a boiler in budget season is also, whether it discusses it or not, deciding what letter is on the door for the next several years.
How it relates to Local Law 97
The two are commonly confused and they are different instruments.
- Local Law 33 is disclosure. It publishes a grade. The penalty is for not posting.
- Local Law 97 is a cap. It sets emissions limits per building type and penalises exceeding them, with limits tightening over time.
They share a threshold — 25,000 square feet — and they share an underlying data source in benchmarking, which is why a building that neglects its benchmarking obligation manages to fail on several fronts simultaneously: an F on the door, a Local Law 33 violation, and no reliable basis for the Local Law 97 planning it will need shortly.
Getting benchmarking right is therefore the cheapest move available. It is a filing, and it is upstream of everything else in this area.
What to do before 31 October
- Confirm your square footage against the 25,000 threshold. Measure it; do not infer it from the unit count.
- Confirm benchmarking was filed. If it was not, that is the first problem, and the F on the label is only its symptom.
- Download the label on or after 1 October and post it at the entrance — do not wait for a reminder that does not come.
- Photograph the posted label with a date, and keep it in the compliance file.
- If the grade is a D, put it into the capital conversation rather than the compliance one. That is a systems question with a multi-year answer.
Where this sits in management
This is a small annual task with a public consequence, on a one-month window that opens and closes inside the same month, for a subset of buildings defined by floor area rather than anything an owner thinks about day to day.
Tracking which buildings in a portfolio cross the threshold, filing benchmarking on time so the grade reflects reality, and getting the label up inside the window is part of how we run apartment building management and the legal and regulatory compliance calendar.
If your building is over 25,000 square feet and you cannot say what letter is currently on its door, schedule a consultation or call 718-568-9278.
This article is general information, not legal or engineering advice, and reflects requirements as of August 2026. Thresholds, grade bands, dates and penalties change. Confirm your building's obligations with the NYC Department of Buildings.