Local Law 88 NYC: Lighting Upgrades, Submetering, and the 2025 Report
4 min read · Updated 2026-08-13
NYC Local Law 88 guide: lighting upgrade and electrical submetering rules for buildings over 25,000 sq ft and the January 1, 2025 compliance report.
What Local Law 88 Requires
What is Local Law 88 of 2009 in NYC?
Local Law 88 of 2009, as amended by Local Laws 132 and 134 of 2016, requires larger New York City buildings to upgrade lighting in common and non-residential areas to meet current energy code standards and to install electrical submeters for large non-residential tenant spaces. It applies to "covered buildings" — generally those over 25,000 square feet. The goal is to cut energy waste through efficient lighting and to give large tenants visibility into their own electricity use through submetering. Local Law 88 is part of NYC's Greener, Greater Buildings suite of energy laws, sitting alongside benchmarking, energy audits, and emissions caps.
Which buildings are covered by Local Law 88?
Local Law 88 generally applies to "covered buildings," which are those larger than 25,000 square feet. The law's coverage tracks the same size threshold used across NYC's energy laws, so many buildings already subject to benchmarking under Local Law 84 also fall under Local Law 88. Within covered buildings, the lighting upgrade requirement targets common areas and non-residential spaces, while the submetering requirement targets large non-residential tenant spaces. Residential dwelling-unit interiors are largely exempt from the lighting upgrade mandate. Owners and managers should confirm their building's square footage and use mix to determine exactly which Local Law 88 obligations apply.
Are apartments exempt from the Local Law 88 lighting upgrade?
Largely, yes. Local Law 88's lighting upgrade mandate focuses on common areas and non-residential spaces within covered buildings, and residential dwelling-unit interiors are largely exempt from the requirement. That means the lighting inside individual apartments generally does not have to be upgraded to satisfy Local Law 88, while lobbies, hallways, stairwells, garages, mechanical rooms, and commercial spaces do. Managers of residential buildings over 25,000 square feet should still expect the common-area lighting requirement to apply, and should not assume the whole building is exempt simply because it is residential. Confirm scope against the DOB Local Law 88 guidance for your specific building.
The 2025 Compliance Report
When was the Local Law 88 compliance report due?
Covered buildings had to complete their lighting upgrades and submeter installations and submit a compliance report by January 1, 2025, filed with the NYC Department of Buildings (DOB). This deadline has now passed, so owners of covered buildings over 25,000 square feet should have already documented that their common and non-residential lighting meets the energy code and that required submeters are installed for large non-residential tenant spaces. If a covered building has not filed, the owner remains out of compliance and should address the requirement promptly, since the obligation did not disappear when the deadline passed. Check DOB records to confirm your building's filing status.
How do I file a Local Law 88 report in NYC?
Local Law 88 compliance reports are filed with the NYC Department of Buildings (DOB) documenting that the covered building's lighting has been upgraded to meet the energy code and that electrical submeters have been installed for large non-residential tenant spaces. The report typically requires certification by a qualified professional confirming the work. Owners who have not yet filed, despite the January 1, 2025 deadline, should engage the appropriate professional to assess the building, complete any outstanding upgrades and submeter installations, and submit the required documentation. Consult the DOB Local Law 88 page for the current filing procedure and forms, since submission methods can change.
What happens if I missed the Local Law 88 deadline?
The January 1, 2025 Local Law 88 compliance deadline has passed, and a covered building that has not upgraded its lighting, installed required submeters, and filed its report remains out of compliance and exposed to NYC Department of Buildings (DOB) enforcement and civil penalties. The requirement does not expire simply because the date passed. Owners in this position should act promptly: assess the building, complete the lighting upgrades and submetering, and file the compliance report. Because penalty specifics can change, confirm current figures through DOB. Addressing a late filing proactively is far better than waiting for a violation to force the work under deadline pressure.
Submetering and the Energy Law Family
What does Local Law 88 require for electrical submetering?
Local Law 88 requires covered buildings to install electrical submeters for large non-residential tenant spaces so that those tenants can see their own electricity consumption. Submetering separates a large commercial tenant's usage from the building master meter, which encourages energy conservation because tenants who see their real consumption tend to reduce waste. The requirement targets sizable non-residential spaces rather than every tenant. Managers should confirm which tenant spaces meet the threshold, ensure compliant submeters are installed, and document the installation as part of the Local Law 88 compliance report. Submetering also supports fairer cost allocation and better data for building energy management.
How does Local Law 88 relate to Local Law 97 and benchmarking?
Local Law 88 is part of the same family of NYC energy laws as Local Law 84 (benchmarking), Local Law 87 (energy audits and retro-commissioning), and Local Law 97 (greenhouse gas emissions caps). Together they push large buildings to measure, disclose, and cut energy use and emissions. Local Law 88's efficient lighting and submetering directly reduce electricity consumption, which helps a building's benchmarking scores under Local Law 84 and can ease compliance with Local Law 97 emissions limits. Managers benefit from treating these obligations as a coordinated program rather than isolated filings, since upgrades made for one law often advance compliance with the others.