Boston building owners may still need to address 2025 emissions after completing their 2026 BERDO reporting. 

An alternative compliance payment can address emissions overages. The payment deadline needs its own review, including the timing of the City’s notice.

Check the payment deadline attached to your BERDO notice

The detail I want owners to pay attention to is when they receive the City’s payment notification. For some Boston properties, an alternative compliance payment connected to 2025 energy use may come due this fall. The notification timing can affect how much time the owner has to arrange that payment.

For owners notified in October 2026 of an alternative compliance payment due for 2025 emissions, the payment deadline is November 15, 2026. For owners notified in November 2026, the payment deadline is December 15, 2026.

Check the notice for the building and compliance year it covers, the amount due, and the payment instructions. Make sure the person arranging payment has that information. An annual deadline calendar can provide context, but the City notice needs a building-specific review before anyone relies on a due date.

Why a 2026 BERDO payment can relate to 2025 energy use

Boston’s Building Emissions Reduction and Disclosure Ordinance (BERDO) requires covered owners to report the previous calendar year’s energy and water use, which are used to calculate the emissions for that year. The 2026 reporting cycle therefore addresses 2025 data. For a building subject to a 2025 emissions standard, an emissions overage from that year can still require attention during 2026.

Boston’s size-based emissions schedule generally places residential buildings with 35 or more units and nonresidential buildings of at least 35,000 square feet in the group that began emissions compliance in 2025. Smaller covered buildings generally begin in 2030. Confirm the City’s classification for the building or parcel, together with any approved flexibility measure, before determining which standard applies.

Payment exposure depends on the applicable emissions limit, the reported emissions, and the compliance mechanisms the owner uses. A building can have an annual reporting obligation without owing an alternative compliance payment.

What is a BERDO alternative compliance payment?

An alternative compliance payment, or ACP, allows a building owner to mitigate emissions above the applicable BERDO limit. Boston’s published guidance currently sets the ACP rate at $234 per metric ton of carbon dioxide equivalent, or CO2e. ACPs can address emissions from any energy source, and the City directs the money to its Equitable Emissions Investment Fund.

The BERDO ordinance treats ACPs as a compliance mechanism and addresses fines separately. Calling every payment a penalty can obscure what the owner needs to do. An ACP accounts for emissions through an authorized compliance option; owners still need to satisfy the reporting and verification requirements that apply to their buildings.

Use the reporting record to review the payment

Boston’s reporting process includes energy and water data in ENERGY STAR Portfolio Manager, a separate BERDO Reporting Form, and third-party verification when required. Review the reporting record alongside the payment notice so the compliance year and building information are clear.

For owners choosing an ACP, the City directs them to the Mitigation of Emissions section of the BERDO Reporting Portal and the Request Invoice option to begin the payment process. The same City guidance explains how qualifying renewable energy certificates can address electricity emissions. The option that applies depends on the building’s emissions and the measures reflected in its reporting record.

Keep the notice, invoice, and payment confirmation with the supporting compliance records. When the amount or deadline needs clarification, resolve the question with the City rather than assuming that a reporting extension or another compliance date also extends the payment deadline.

Other year-end BERDO deadlines cover different actions

Boston listed October 15, 2026, as the annual reporting deadline for owners with approved extensions. That reporting milestone is separate from the year-end requirements for owners who choose renewable energy certificates. Each date relates to a particular action and a particular group of owners.

October 31, 2026: Purchases through the City REC Connector

Owners using the City’s MA Class I REC Connector Program for 2025 emissions compliance must purchase their qualifying renewable energy certificates (RECs) by October 31, 2026. This is an optional purchase route. Owners may also purchase qualifying RECs independently, subject to BERDO requirements. The October 31 deadline applies to the Connector purchase route, rather than every BERDO compliance option.

December 31, 2026: REC retirement and supporting documentation

For RECs used toward 2025 compliance, Boston’s adopted regulations require retirement no later than December 31, 2026. Retirement removes the certificates from circulation so another party cannot claim them. When retirement occurs after the applicable annual reporting deadline, owners must submit proof within 30 days of retirement and no later than December 31. A REC purchase and its retirement documentation are separate parts of the record.

Keep 2026 performance separate from 2027 reporting

I also want owners to keep the next reporting cycle in view. Buildings already subject to emissions standards are in their 2026 performance year while owners may still be resolving 2025 compliance. Energy use during 2026 will form the basis of the following year’s report.

Boston’s ordinary annual reporting deadline is May 15. Under that schedule, owners would report 2026 energy and water use by May 15, 2027, unless the City establishes a different deadline or approves an applicable extension. The reporting deadline and the timing of a later payment notice should remain separate entries in the property’s calendar.