Massachusetts Large Building Energy Reporting (LBER): What Commercial Property Owners Need to Know

Massachusetts is continuing to expand its focus on building energy performance and decarbonization through the implementation of Massachusetts Large Building Energy Reporting (LBER) requirements. As commercial real estate owners, developers, property managers, and institutions navigate evolving compliance obligations, understanding how the Massachusetts building energy reporting law impacts operations and reporting responsibilities is becoming increasingly important.

For organizations with properties throughout Massachusetts, LBER introduces annual building energy benchmarking and reporting requirements focused on energy usage transparency and long-term sustainability goals. While the regulation is currently centered on benchmarking and disclosure, it also signals a broader statewide movement toward energy efficiency, greenhouse gas reduction, and future building performance standards.

What Is LBER?

Large Building Energy Reporting (LBER) is a statewide Massachusetts energy disclosure and building benchmarking program administered by the Massachusetts Department of Energy Resources (DOER). Established under the Commonwealth’s climate legislation, the program requires owners of certain large buildings to annually report energy consumption data.

LBER is implemented under Massachusetts regulation 225 CMR 27.00, which establishes the statewide reporting framework and outlines owner compliance obligations, reporting timelines, and public disclosure requirements.

The purpose of the regulation is to improve visibility into building energy performance across Massachusetts while supporting statewide climate and decarbonization initiatives.

LBER is similar in concept to local building benchmarking ordinances already in place in municipalities such as Boston BERDO and Cambridge BEUDO, but it applies at the state level across Massachusetts.

Which Buildings Are Covered Under LBER?

LBER generally applies to buildings that are:

• 20,000 square feet or larger
• Commercial properties
• Multifamily residential buildings
• Institutional facilities
• Industrial buildings
• Mixed-use properties

Covered building owners may be required to report energy consumption associated with:

• Electricity
• Natural gas
• Steam
• Fuel oil
• Propane
• Biomass fuels
• On-site renewable energy systems

Because building ownership structures, tenant arrangements, and utility configurations can vary significantly, determining whether a property qualifies under the regulation may require detailed review and coordination.

Building owners can review the state’s annual Covered Buildings List published by DOER.

LBER Reporting Deadlines

Massachusetts has established an annual reporting cycle for covered buildings. Key milestones generally include:

• March 30: Covered Buildings List published
• May 30: Utility companies submit energy usage data
• June 30: Building owners submit additional energy information
• October 31: Public disclosure data published by DOER

Owners should continue monitoring updates from DOER, as reporting procedures, benchmarking guidance, and implementation details may continue evolving as the program matures.

Public Disclosure and Transparency

One of the most significant aspects of LBER is the public disclosure component associated with the program. Following the annual reporting cycle, the Massachusetts Department of Energy Resources (DOER) may publish building-level energy performance and greenhouse gas emissions data for covered properties.

As building energy benchmarking and transparency requirements continue expanding nationwide, publicly available performance data may become increasingly relevant to:

• Investors
• Lenders
• Prospective tenants
• Municipal agencies
• Insurance providers
• Asset managers

For many organizations, publicly disclosed energy benchmarking data can influence broader discussions around operational performance, ESG initiatives, sustainability goals, capital planning, and long-term asset competitiveness.

LBER vs. BERDO: Understanding the Difference

One of the most common areas of confusion is the distinction between LBER and Boston’s BERDO program.

LBER

• Statewide Massachusetts regulation
• Focused on annual energy reporting and building benchmarking
• Managed by Massachusetts DOER
• Applies to covered large buildings across the Commonwealth

BERDO

• Boston-specific ordinance
• Includes building emissions limits and compliance pathways
• Managed by the City of Boston
• Applies only to qualifying Boston properties

Some properties may overlap between programs, particularly in Boston and Cambridge, but compliance requirements and reporting obligations are not always identical.

Why LBER Matters for Commercial Real Estate

As environmental reporting and building benchmarking requirements continue expanding nationwide, LBER adds another important layer to the evolving commercial real estate compliance landscape.

Building energy performance data is becoming increasingly important to investors, lenders, tenants, property owners, and asset managers evaluating operational efficiency, long-term sustainability, and asset risk exposure.

In many cases, energy reporting requirements are influencing broader conversations around ESG initiatives, deferred maintenance planning, decarbonization strategies, capital improvements, tenant utility coordination, operational efficiency, and overall asset valuation.

Organizations utilizing benchmarking platforms such as ENERGY STAR® Portfolio Manager® may already have foundational systems in place that can support LBER compliance and annual reporting efforts.

For many building owners, proactive planning can help reduce compliance challenges while also identifying opportunities for operational improvements and long-term energy savings.

Common Challenges Building Owners Face

Many property owners and managers are encountering practical challenges while preparing for compliance, including:

• Collecting tenant utility data
• Managing multiple utility accounts
• Tracking delivered fuels
• Understanding building square footage calculations
• Coordinating campus-style properties
• Identifying exemptions
• Navigating evolving state guidance
• Integrating benchmarking platforms and reporting tools

Older buildings and complex ownership structures may require additional coordination, utility analysis, and data management support.

Potential Penalties for Noncompliance

Building owners are responsible for complying with applicable LBER reporting requirements and submission deadlines. Under the Massachusetts framework, failure to comply with reporting obligations may result in civil penalties.

As currently outlined under the regulation, penalties may reach up to $150 per day for ongoing noncompliance. Because regulatory guidance may evolve over time, property owners should continue monitoring updates issued by DOER regarding enforcement procedures and reporting expectations.

How Hillmann Can Help

At Hillmann Consulting, our team understands the operational, environmental, and compliance challenges facing commercial real estate owners throughout Massachusetts and across the Northeast.

Hillmann helps commercial real estate owners, developers, lenders, institutions, and property managers navigate evolving energy reporting, building benchmarking, and building performance requirements throughout Massachusetts.

Our multidisciplinary services can support organizations navigating LBER compliance and broader building performance initiatives, including:

• Energy benchmarking support
• ENERGY STAR® Portfolio Manager assistance
• Building data collection and organization
• ESG and sustainability consulting
• Energy audits and efficiency evaluations
• Decarbonization planning
• Property condition assessments
• Indoor Air Quality (IAQ) consulting
• Construction and capital planning advisory services

As regulatory requirements continue evolving, having a strategic approach to energy benchmarking and building performance can help property owners better position assets for long-term operational and investment goals.

Preparing for the Future of Building Performance Regulations

While LBER is currently focused on energy reporting and transparency, many industry professionals view it as part of a broader trend toward increased building performance standards and greenhouse gas emissions reduction requirements.

Organizations that begin organizing building data, benchmarking energy usage, and evaluating long-term efficiency opportunities now may be better positioned for future regulatory expectations, investor scrutiny, and evolving market demands.

Learn more about Hillmann’s Building Science, Due Diligence, Energy, Development Management, and Construction Services.