Tier 2 compliance is due July 1, 2027·8 months away·Only 6.7% of covered buildings had complied as of September 2026Start your assessment →
Menu
HomeThe RequirementThe IncentiveWhy UsOngoing ComplianceFAQResourcesContact
(206) 371-0795Request an assessment

Home / Ongoing Compliance

Ongoing Compliance and Reporting

The 2027 filing isn’t a one-time job. Tier 2 owners report to the Washington State Department of Commerce every five years, and the benchmarking, Energy Management Plan and Operations and Maintenance Program behind the filing have to be kept up in between. Owners who let them lapse end up rebuilding them under deadline in 2032.

What continues after the filing

  • Benchmarking does not stop. The ENERGY STAR Portfolio Manager record must be kept current with utility data, meter changes, occupancy changes and corrections, so the next report has five years of clean history behind it.
  • The plan and the program are living documents. Equipment is replaced, tenants change, operating hours shift, and the documents the Department of Commerce accepted in 2027 are expected to describe the building as it actually operates when the 2032 report is due.
  • The State portal and the owner's accounts persist. Building IDs, Secure Access Washington credentials, shared-access designations and the designated Qualified Energy Manager of record all have to be kept current, particularly through a sale, a refinancing or a change of management.
  • The rules move. The Department of Commerce has already amended WAC 194-50 and its reporting tools since the program began, has recommended expanding Tier 2 incentives to cover building improvements, and the standard itself is due for an update. Someone has to keep track of the changes.
  • Buildings cross thresholds. An addition, a change of use, or a reclassification of parking or unconditioned space can move a building between tiers or into coverage. The City of Seattle's separate benchmarking and performance requirements add a second calendar for buildings inside the city.

Our ongoing compliance service

For clients who want the obligation handled continuously rather than every five years, one of our Qualified Energy Managers remains designated for the building and our team carries the work between reports:

  • Annual benchmarking update and reconciliation of the Portfolio Manager record, with a written annual compliance status for the owner's files.
  • Maintenance of the Energy Management Plan and Operations and Maintenance Program as the building changes, so the next filing only needs updating.
  • Portal and account administration, including changes of ownership, management or utility.
  • Monitoring of the standard, the Department of Commerce's guidance and incentive programs, with notice to the owner when something affects the building.
  • Preparation and submission of the five-year report when it comes due, and of any incentive application the State offers at that time.
  • For buildings in Seattle, coordination of the State and City requirements on one calendar.

The service is offered as a flat annual retainer per building, with portfolio pricing, and is available to any building we filed for and to owners whose 2027 filing was prepared elsewhere.

Complying in 2027 doesn’t carry over to 2032. The next report depends on five years of records, so someone has to keep them.

Ask us about ongoing compliance for a building or a portfolio.