Boston’s extended August 15 reporting deadline is followed closely by a September 1 deadline for several BERDO flexibility measures.
Building Portfolios, Individual Compliance Schedules, hardship plans, and renewable-energy options address different parts of emissions compliance, so owners should understand the distinctions before choosing a path.
THE AUGUST 15 REPORTING DEADLINE CAN LEAD TO A SEPTEMBER 1 DECISION
Boston building owners subject to the Building Emissions Reduction and Disclosure Ordinance (BERDO) have an extended annual reporting deadline of August 15, 2026. Several flexibility-measure deadlines follow 17 days later, on September 1.
The short interval matters because annual reporting, third-party verification, emissions compliance, flexibility measures, and renewable-energy procurement are separate parts of BERDO. Completing the annual report supplies the data the City uses to evaluate a building, but it does not by itself resolve whether the building is within its emissions limit or whether a flexibility measure is appropriate.
The City’s current Review Board deadline table lists September 1, 2026 for Building Portfolio, Individual Compliance Schedule, Short-Term Hardship Compliance Plan, and Streamlined Short-Term Hardship Compliance Plan applications. Building Portfolio and Individual Compliance Schedule applications may be applied to 2025 or 2026 emissions. The two short-term hardship pathways are listed for 2025 emissions.
At a glance: 2026 BERDO deadlines
- August 15: Extended 2026 annual reporting deadline for BERDO building owners.
- September 1: Building Portfolio and Individual Compliance Schedule applications for 2025 or 2026 emissions; Short-Term and Streamlined Short-Term Hardship applications for 2025 emissions.
- October 31: City REC Connector Program purchase deadline for eligible MA Class I RECs used for 2025 emissions compliance.
For broader BERDO context, read BERDO Compliance in 2026: Why Boston Building Owners Need a Strategy, Not Just a Deadline.
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 BERDO FLEXIBILITY MEASURES REQUIRE REVIEW BOARD APPROVAL?
The BERDO Review Board must approve Building Portfolios, Individual Compliance Schedules, and Hardship Compliance Plans. A Blended Emissions Standard does not require a separate Review Board application; an eligible owner opts in through the BERDO Reporting Portal during the first emissions-compliance reporting cycle or a later verification year.
How the main options differ
- Blended Emissions Standard. Recalculates the emissions standard for a building or approved portfolio with multiple primary uses. No separate Review Board application is required; an eligible owner opts in through reporting during the first compliance year or a verification year.
- Building Portfolio. Replaces building-by-building limits with a portfolio-wide Blended Emissions Standard. Review Board approval is required, with a September 1, 2026 deadline.
- Individual Compliance Schedule. Creates an absolute emissions-reduction schedule from an eligible historical baseline. Review Board approval is required, with a September 1, 2026 deadline.
- Short-Term Hardship Compliance Plan. Provides eligible relief for one to three years through an alternative timeline, limit, or other approved measure. Review Board approval is required, with a September 1, 2026 deadline for 2025 emissions.
- Streamlined Short-Term Hardship Compliance Plan. Provides a simplified pathway for qualifying under-resourced or equity priority building owners. Review Board approval is required, with a September 1, 2026 deadline for 2025 emissions.
The options can interact, but they are not interchangeable. A Building Portfolio may be combined with an Individual Compliance Schedule or a Hardship Compliance Plan. An Individual Compliance Schedule may be combined with a Building Portfolio. A Hardship Compliance Plan may be combined with a Building Portfolio.
WHAT IS A BERDO BUILDING PORTFOLIO?
A Building Portfolio allows an owner to group eligible BERDO buildings and comply with one portfolio-wide Blended Emissions Standard. This can give owners more flexibility to coordinate emissions reductions with capital planning across several properties, because improvements at one building may help the portfolio meet the aggregate standard.
The current Flexibility Measures Quick Guide states that the buildings must have the same owner or be part of the same Institutional Master Plan. The application also asks owners to demonstrate that building uses, gross floor area, and annual energy and emissions data were third-party verified during the last verification year; that the buildings are current with applicable reporting, verification, and emissions requirements; and that the portfolio contains no vacant buildings.
A Building Portfolio remains subject to annual emissions requirements. The portfolio must meet its portfolio-wide Blended Emissions Standard in each compliance year and reach net-zero emissions by 2050. Review Board approval may also carry standard or special conditions, depending on the application pathway and the characteristics of the proposed portfolio.
The practical evaluation should begin with the proposed portfolio calculation. If the portfolio-wide standard does not improve the owner’s compliance position or capital plan, the administrative work of creating a portfolio may not provide a meaningful advantage. Owners should also determine whether any property condition, ownership structure, vacancy, or data issue affects eligibility before entering the online application.
WHAT IS A BERDO INDIVIDUAL COMPLIANCE SCHEDULE?
An Individual Compliance Schedule (ICS) uses an eligible historical baseline rather than the default use-based emissions-intensity schedule. The owner selects a baseline year between 2005 and 2021 and proposes an absolute emissions-reduction path for the building or Building Portfolio.
The required trajectory remains substantial. The building or portfolio must reduce total emissions by 50% by 2030 and 100% by 2050 from the selected baseline, with emissions limits declining linearly or better in five-year increments.
The City’s quick guide identifies several data and eligibility points that should be tested before an owner relies on this option. The baseline-year building uses, gross floor area, annual energy data, and emissions data must be available for third-party verification. Each building’s total gross floor area generally cannot have been reduced by more than 10% from the baseline year, and the largest primary use must remain the same. The building must also be current with applicable BERDO obligations.
An ICS may be relevant when an owner has reliable historic records and has already completed meaningful emissions-reduction work that the default schedule does not fully recognize. It may be a poor fit when the baseline record is incomplete, the building changed materially, or the absolute reduction schedule produces a less favorable result than the standard pathway. The City provides an ICS calculation template so owners can test the proposed schedule before applying.
WHEN CAN A SHORT-TERM HARDSHIP COMPLIANCE PLAN APPLY?
A Hardship Compliance Plan (HCP) allows the Review Board to approve an alternative emissions-reduction timeline, alternative emissions standard, or other eligible relief when a building owner demonstrates a qualifying hardship. Short-term plans generally cover one to three years. Long-term plans cover four or more years; the 2026 deadline for a long-term HCP was July 1.
City guidance identifies several types of circumstances that may support a hardship analysis. Examples include unavailable space, equipment, or electric service needed for compliance; effects on the ability or cost to provide services critical to community health and safety; and unreasonable cost difficulty for the building owner. The application requires evidence tying the building’s specific conditions, the available BERDO options, and the requested relief to an eligible hardship.
An HCP does not suspend annual reporting or third-party verification. Owners must continue reducing emissions under the approved plan, and the Review Board may attach conditions. The application packet asks the owner to document the building, prior emissions-reduction work, the compliance options considered, available financial support, the circumstances causing the hardship, supporting evidence, and the proposed relief.
The Streamlined Short-Term HCP is a simplified pathway for qualifying under-resourced and equity priority building owners with buildings above the 2025 emissions limit. The City identifies potential categories that include deed-restricted affordable housing, qualifying condominium or cooperative buildings, qualifying rental housing, small businesses, and small nonprofit organizations. Eligibility still must be demonstrated through the current application. The City’s March 2026 flexibility-measures webinar describes the streamlined pathway as providing relief for 2025 through 2027 through an alternative emissions limit based on average past emissions data.
WHAT SHOULD OWNERS REVIEW BEFORE SEPTEMBER 1?
- Owners evaluating a September 1 application should prepare the technical record before selecting a pathway:
- Complete and validate the annual reporting record. Confirm the ENERGY STAR Portfolio Manager data, BERDO Reporting Form, building characteristics, primary uses, and third-party verification status.
- Compare reported emissions with the applicable standard. Separate electricity-related emissions from fossil-fuel emissions because renewable-energy options affect only the electricity portion.
- Test the proposed measure before applying. Calculate a building-level or portfolio-level Blended Emissions Standard, test the ICS schedule, or quantify the relief requested through an HCP.
- Confirm eligibility and ownership information. Review portfolio ownership, Institutional Master Plan status, vacancies, current compliance, gross floor area, primary-use history, and baseline records.
- Assemble supporting evidence. HCP applicants should document the conditions causing the hardship, available compliance options, project barriers, costs, financial support, prior reduction work, and the requested alternative.
- Prepare the application outside the portal. The City’s 2026 webinar states that the Building Portfolio and ICS online forms cannot be saved and resumed. Review the PDF application and templates, prepare complete answers, and then enter the form in one session.
- Allow time for review and revisions. Submission does not equal approval. The Environment Department reviews applications for completeness, and the Review Board may approve with standard or special conditions or deny the request.
- The September 1 filing is a near-term decision. The selected pathway should still fit the building’s capital plan, energy profile, operating constraints, and longer-term route to net-zero emissions.
HOW EBI SUPPORTS BERDO PLANNING
EBI’s Energy & Sustainability Services team supports building owners through Energy Benchmarking and Building Performance Standards Reporting. Accurate building data, a clear emissions profile, and a practical understanding of the available pathways can help owners make better-informed decisions before a filing deadline and within the longer-term capital plan.
Discuss BERDO reporting and planning with EBI.