2026 is shaping up to be a pivotal year for facilities managers as building performance standards (BPS) advance across key jurisdictions, specifically in the states of Colorado, Maryland, and Washington. These leaders play a vital role in shaping compliance strategies and driving long-term carbon and energy performance, transforming regulatory requirements into strategic investments that enhance property value, employee well-being, and sustainability stewardship. Facilities managers are now at the forefront of navigating complex compliance deadlines, evolving reporting rules, and ambitious long-term performance targets.
The stakes are high: Non-compliance exposes organizations to significant financial risks, including escalating penalties that can reach thousands of dollars per day, legal actions, and operational disruptions such as stop-work orders or even revoked operating licenses. For example, in Boulder, benchmarking violations can lead to fines of up to $1,000 per day, while at the state level in Colorado, failing to meet BPS regulations can result in an initial penalty of $2,000, followed by ongoing monthly fines of $5,000 until compliance is achieved.
However, organizations that act early stand to gain substantial advantages. Early compliance not only secures access to the most generous rebates, tax credits, and grant programs before funds are depleted, but also locks in contractor availability and resources at better rates. These proactive steps can potentially deliver financial, operational, and reputational benefits, including lower operating costs, stronger environmental, social, and governance (ESG) outcomes, and greater resilience against extreme weather and grid disruptions.
Step 1: Assessing the Portfolio and Mapping Requirements
The first step for facilities managers is to assess current building performance and determine the gap between today’s operations and required targets. This is especially critical as different jurisdictions operate on different compliance clocks requiring facility teams to plan at the portfolio level, mapping out requirements and deadlines for each location.
For instance, the Building Performance Colorado program requires buildings over 50,000 square feet to meet phased energy use intensity (EUI) or greenhouse gas intensity (GHGI) targets by 2030 with stricter targets likely in 2040. To add to the complexity, various locales within the state such as Boulder and Denver have their own requirements, lowering building size thresholds and requiring different timelines and actions for compliance.
Maryland’s Building Energy Performance Standards mandate a 20% GHG reduction by 2030, 60% by 2035, and net-zero by 2040, while Montgomery County sets its own EUI-based targets with final deadlines as early as 2033. Washington’s Clean Buildings Performance Standard starts compliance cycles in 2026, requiring energy management plans and operations and maintenance enhancements in addition to meeting EUI targets—while Seattle has GHGI targets with reporting starting in 2027.
Step 2: Understanding Benchmarking and Establishing a Reliable Process
Accurate benchmarking is foundational to compliance, as it establishes the baseline against which performance improvements are measured. ENERGY STAR Portfolio Manager is a widely used tool for this purpose, but its effectiveness depends on consistent, verified data entry and a streamlined approach to data collection. Centralizing data collection, by consolidating utility, energy, and water data from across departments and third-party systems, ensures that information is standardized, validated, and readily available for compliance reporting.
Managing a building portfolio through a single provider with expertise in portfolio-wide BPS regulations can offer significant advantages. Such an approach simplifies compliance by providing clear visibility into evolving requirements, deadlines, and risks across all jurisdictions where an organization operates. Monthly benchmarking across the entire portfolio not only prepares organizations for annual reporting but also highlights performance gaps before they become liabilities, enabling proactive decision-making.
In addition to data management, a comprehensive provider can support on-site audits and deliver the necessary skill sets and certifications, such as Certified Energy Managers and ASHRAE Level II auditors, to fulfill compliance requirements. These teams conduct site-level assessments, verify data accuracy, and produce actionable roadmaps tailored to each property’s needs and local regulations. This end-to-end support streamlines compliance, reduces administrative burden, and positions organizations to unlock incentives, avoid penalties, and drive continuous improvement in building performance.
Establishing a reliable process for benchmarking and compliance, one that centralizes data, leverages specialized expertise, and ensures consistency across the portfolio, is essential for facilities managers. Such a process not only fulfills regulatory requirements but also empowers organizations to proactively manage risk, optimize building performance, and stay ahead in a rapidly evolving regulatory landscape.
Step 3: Building the Roadmap to Meet Targets
Facilities managers must develop a phased roadmap based on identified performance gaps, capital cycles, and organizational priorities. This roadmap should be dynamic and comprehensive, integrating not only technical upgrades but also financial and risk considerations to maximize value and resilience.
A robust roadmap typically begins with a thorough energy audit, preferably an ASHRAE Level II audit, which provides a detailed assessment of current building performance and pinpoints the most impactful opportunities for improvement. These audits help prioritize measures such as energy efficiency upgrades (advanced HVAC systems, LED lighting, and smart controls), electrification of building systems, renewable energy procurement, operations and maintenance enhancements, and building envelope improvements. Each of these measures contributes to reducing energy consumption, lowering greenhouse gas emissions, and improving overall building performance.
Importantly, facilities managers should actively seek out and incorporate available rebates, tax credits, and grant programs into their roadmap. Early compliance with BPS often unlocks the most generous incentives, which can significantly offset upfront capital costs. For example, Colorado and Washington offer enterprise funds and early adopter incentives, but these resources are limited and tend to diminish as deadlines approach. By acting early, organizations can secure these financial benefits before funds are depleted or requirements become more stringent.
Conclusion
Achieving compliance with BPS is a multi-year journey, not a quick fix. Facilities teams that start now can avoid costly penalties, unexpected capital demands, and last-minute retrofits. As BPS regulations mature and expand, facility leadership must treat 2026 as the year of action to stay ahead of the curve, secure incentives, and position their organizations for long-term success in a rapidly evolving regulatory landscape. Facilities managers who lead the charge will not only safeguard their organizations from risk but also unlock new opportunities for value creation, resilience, and sustainability.
Craig Walter, principal energy advisor at ENGIE Impact, has 30 years of experience in the energy management industry, using total energy and sustainability management programs to help clients reduce their consumption and cost, from individual sites to large, multi-site commercial portfolios. Walter now guides program development and solutions for ENGIE Impact’s energy management services.