Denver Construction and Demolition Recycling Requirements: Planning for September 1, 2026

Denver’s construction and demolition recycling requirements apply to qualifying permit applications submitted on or after September 1, 2026.

Project teams should account for the waste diversion plan, performance security deposit, diversion target, closeout documentation, and separate handling of asbestos, lead, and hazardous materials.

Denver URCO Construction and Demolition Requirements at a Glance 

Denver’s construction and demolition recycling requirements under the Universal Recycling and Composting Ordinance (URCO) affect permit planning, budgets, contracts, schedules, trade scopes, material routes, and closeout. The formal duties sit with the contractor or permit holder, while owners, developers, lenders, and investors carry the related business and project risk. 

• Effective date. Qualifying permit applications submitted on or after September 1, 2026. 

• New construction or demolition. Projects over 500 square feet. 

• Interior remodel or tenant work. Projects over 2,500 square feet. 

• Before permit issuance. Waste diversion plan, performance security deposit, and at least three covered material types. 

• During the work. A 50% diversion target by weight, hauler and destination coordination, and itemized records as work proceeds. 

• At closeout. Records submitted within 60 days after final inspection; the refund is tied to the documented diversion rate, with a full refund at 50% or more. 

• Separate materials. Asbestos, lead, and other hazardous materials are handled outside the diversion calculation; state asbestos approval remains a separate demolition step. 

WHAT HAPPENS AFTER BERDO REPORTING? 

BERDO reporting has three main components: reporting building characteristics and annual energy and water use through ENERGY STAR Portfolio Manager, completing the BERDO Reporting Form, and completing third-party verification when required. In 2026, third-party verification is required for buildings reporting their first emissions compliance year and for other buildings in a verification year. 

That reporting record supports the next set of questions. Is the building over its applicable emissions standard? How much of the reported emissions comes from electricity and how much comes from on-site fossil-fuel use? Does the property have multiple primary uses? Does the owner control several BERDO buildings? Is verified historical data available? Are there documented technical or financial conditions that make the standard timeline extraordinarily difficult? 

Those questions point to different BERDO pathways. A mixed-use building may be eligible to use a Blended Emissions Standard. A multi-building owner may evaluate a Building Portfolio. An owner with suitable historical data may consider an Individual Compliance Schedule. A building facing an eligible hardship may need to evaluate a Hardship Compliance Plan. Renewable-energy options such as a Power Purchase Agreement address electricity-related emissions through a separate compliance mechanism. 

Which Denver Projects Are Covered? 

The requirements apply to qualifying permit applications submitted on or after September 1, 2026, for work permitted by the City and County of Denver. The project type and size determine whether the construction and demolition requirements may apply. 

• New construction or demolition. Projects over 500 square feet. 

• Interior remodel, alteration, or tenant work. Projects over 2,500 square feet. 

The screening should happen while a project is still in capital planning, redevelopment planning, design, or preconstruction. Additions, major renovations, larger tenant improvements, and demolition work can all create a reason to review the permit path before budgets, contracts, and schedules are final. 

What the Requirements Add to the Project Lifecycle 

Before Permit Issuance 

The contractor or permit holder must account for a waste diversion plan, the performance security deposit, and a strategy that includes at least three covered material types. Owners, developers, and project sponsors should define who funds the deposit and who manages the plan before the permit schedule and construction agreements are finalized. 

Contractors and delivery teams should also place material separation, hauler coordination, destination planning, and recordkeeping responsibilities into the trade plan. Lenders and investors can use the same stage to test whether permit readiness and project cash flow assumptions reflect the new requirements. 

During Construction or Demolition 

Qualifying projects carry a 50% diversion target by weight. The work plan should align haulers, recycling or reuse destinations, trade responsibilities, and itemized records as the project proceeds. The project team should know who collects weights, receipts, photos, and other supporting records rather than leaving that task to the end of the job. 

At Project Closeout 

Compliance records are due within 60 days after final inspection. The performance security deposit refund is tied to the documented diversion result, and projects that document 50% or more can receive a full refund. Because the closeout package depends on records created during the work, documentation belongs in the project controls from the beginning. 

The Performance Security Deposit Belongs in the Budget 

The performance security deposit is a pre-permit requirement and can be material for larger projects. Through 2035, deposits can reach $200,000 for larger new construction or demolition work and $100,000 for larger renovation or tenant-finish work. 

Owners and developers should identify who will fund the deposit, who will control the related documentation, and how a partial or no refund will be handled in the contract. Contractors should include deposit administration in the permit and closeout plan. Lenders and investors should confirm that the budget and cash-flow assumptions account for both deposit funding and the possibility that the full amount may not be returned. 

Asbestos, Lead, and Hazardous Materials Follow a Separate Path 

Materials containing asbestos or lead, along with other hazardous materials, are excluded from the debris total used for the diversion calculation. These materials still need a separate assessment, handling, and documentation path within the overall project plan. 

For demolition work, state asbestos approval remains a separate step before the Denver demolition permit process can move forward. Early building-material and site-condition information helps the team coordinate abatement, demolition, recycling, hauling, and disposal scopes without treating regulated materials as ordinary construction debris. 

What Property Owners, Developers, and Project Sponsors Should Review 

Owners and developers carry the project exposure even when the contractor or permit holder manages the formal submissions. Four planning decisions deserve early attention: 

• Screen the capital plan. Identify Denver redevelopment, additions, major renovations, larger tenant improvements, new construction, and demolition work that may cross the project thresholds. 

• Budget the deposit. Include the required funding in project cash flow and decide how a partial or no refund will be treated. 

• Put duties in the contract. Name who funds the deposit, manages the waste diversion plan, directs haulers, keeps itemized records, and submits the closeout package. 

• Separate regulated materials early. Build asbestos, lead, universal-waste, and other environmental review into the project sequence before ordinary debris handling begins. 

This approach gives the owner or sponsor a clearer view of cost, responsibility, and timing through closeout, while allowing the contractor to execute against a defined work plan. 

What Contractors and Project Delivery Teams Should Review 

Contractors and permit holders carry the core planning, deposit, and documentation duties. Architects, construction managers, demolition contractors, and other project partners should support a coordinated permit and trade plan. 

• Build the requirements into the permit path. Include the waste diversion plan, deposit, and covered-material strategy before permit issuance. 

• Assign responsibilities by trade. Define responsibility for separation, hauling, recycling or reuse destinations, and ticket collection. 

• Keep regulated materials separate. Coordinate asbestos, lead, and hazardous-material work outside ordinary debris diversion. 

• Own the closeout record. Assign responsibility for weights, receipts, photos, diversion results, and the submission due within 60 days after final inspection. 

The key operational point is alignment. Permit documents, trade scopes, hauler instructions, material routes, and recordkeeping should tell the same story before work starts. 

What Lenders, Investors, and Capital Providers Should Review 

Denver’s requirements can affect permit readiness, cash flow, environmental allowances, monitoring, closeout, and deposit recovery. Those items should be tested before underwriting, acquisition plans, and construction monitoring scopes are final.

• • Validate deposit funding. Confirm who funds the performance security deposit and whether the budget treats a partial or no refund as a project exposure. 
  • Check permit readiness. The waste diversion plan and deposit come before permit issuance, so they belong in the schedule review. 
  • Test environmental allowances. Asbestos, lead, and other hazardous materials need separate survey, abatement, handling, and disposal assumptions. 
  • Follow closeout evidence. Records are due within 60 days after final inspection, and the documented diversion result affects the deposit refund. 

A lender or investor does not manage the contractor’s formal submissions, but it can require visibility into whether the budget, schedule, monitoring scope, and closeout assumptions reflect the project requirements. 

How EBI Can Support Denver Project Planning 

EBI supports project teams with building-material, site-condition, capital-planning, diligence, and construction-risk information. The contractor or permit holder remains responsible for Denver’s waste diversion plan, performance security deposit, and closeout submissions. 

For Property Owners, Developers, and Project Sponsors 

Relevant EBI capabilities may include Property Condition Assessment and Capital Needs Advisory Services, Asbestos Surveys and Abatement Oversight, Lead Paint and Lead-in-Water Assessments, Universal Waste Surveys, and Soil Pre-Characterization for Construction. 

For Contractors and Project Delivery Teams 

EBI can support preconstruction information and site-condition planning through Asbestos Surveys and Abatement Oversight, Lead Paint and Lead-in-Water Assessments, Universal Waste Surveys, Soil Pre-Characterization for Construction, and Contaminated Soil Management and Disposal where project conditions warrant. 

For Lenders, Investors, and Capital Providers 

Construction risk review may include Plan and Cost Reviews, Construction Monitoring and Status Reports, and Costs-to-Complete Evaluations. Building-material assessment services can also help test environmental assumptions that may affect project scope and cost.