LL84 and LL33, side by side
Both fall on the owner, and clearing one does nothing for the other. The benchmarking report is due 1 May every year and reissues quarterly until it is filed; the energy-grade label is a separate duty on a separate clock in October with its own one-off penalty.
| Where they differ | LL84 — benchmarking report | LL33 — energy-grade label |
|---|---|---|
| The deadline | 1 May, every year | Available in the DOB NOW Public Portal from 1 October; must be printed and displayed near each public entrance within 30 days after 1 October, and must be accessed between 1 October and 31 October |
| What triggers the violation | Being on the Covered Buildings List and not having provided a FULLY COMPLIANT benchmarking report by the 1 May deadline — not merely the absence of a submission | Pay the penalty for failure to timely display the energy efficiency score and grade per 1 RCNY §103-06 (l); pay or challenge through the DOB NOW Public Portal under DOB NOW: Safety - Local Law 33 of 2018. §103-06 reflects LL33/2018 and LL95/2019 and has an effective date of 20 February 2020. |
| The penalty | $500 per violation, issued quarterly until the report is submitted | $1,250 per EGRADE violation |
| How often it reissues | 1 August, then 1 November, then 1 February of the following year | — |
| Annual ceiling | $2,000 per year | — |
| Challenging it | Within 30 days of the Notice of Violation postmark. The challenge request form is submitted through DOB NOW: Safety; sustainability@buildings.nyc.gov is now the follow-up address, not the submission route. | Under 1 RCNY §103-06 (m), a challenge may include but is not limited to: (1) label printing issues — correspondence, a screenshot of the outage, and an email sent to DOB within 30 days of 31 October; (2) the property is exempt from benchmarking — an email from DOF or DOB confirming the exemption; (3) the label was temporarily removed — photographic proof of display plus the reason for removal; (4) the label was posted and the violation is incorrect — photographic proof of display and a description of the entrance locations. |
| Who the duty falls on | The building owner, or a representative the owner assigns. No registered design professional, licensed engineer or architect is required to file a benchmarking report; the owner remains the party the violation is issued against. | The building owner, or a representative the owner assigns. No registered design professional, licensed engineer or architect is required to file a benchmarking report; the owner remains the party the violation is issued against. |
Six things that are LL84’s alone
LL33 has no equivalent for any of them.
Four questions decide which row an owner is actually standing in. Coverage comes first: the notice is issued because the building sits on the LL84 covered buildings list and no benchmarking report has been provided for it, so a building wrongly on the list is corrected rather than filed for. Second, Local Law 84 penalties do not land once — they reissue on a fixed quarterly cycle for as long as the report is missing, which is why the figure an owner remembers from the first notice is rarely the figure now owed. Third, the question of who can file LL84 benchmarking has a wider answer than most owners expect: no licensed professional is required, and the owner or any representative the owner assigns may submit it. Fourth, the cost to cure an LL84 benchmarking violation is the accrued penalty plus whoever files the report, and it has to be assembled from both, because no firm selling Local Law 84 compliance consulting publishes a price for the work. The label duty is worked out separately in the energy-grade label guide.
Every figure above is the value carried in this site’s claim register, re-verified against its primary source on 2026-09-14. Sources: NYC DOB — LL84: NYC Benchmarking Law Violations and NYC DOB — Benchmarking and Energy Efficiency Rating.