Building Performance Colorado vs Energize Denver
How the state program and Denver's city ordinance overlap: thresholds, deadlines, targets, penalties, and what a Denver building owner has to file twice.
Updated 2026-09-19. Facts checked against C.R.S. 25-7-142, Regulation 28, and the Colorado Energy Office. Not legal advice.
These are two separate laws run by two separate governments that happen to regulate the same buildings. Mixing them up is the most common mistake we see, so here is the split.
Who runs what
Building Performance Colorado is state law, C.R.S. 25-7-142, run by the Colorado Energy Office and enforced by CDPHE. Energize Denver is a City and County of Denver ordinance run by the Office of Climate Action, Sustainability and Resiliency. A building inside Denver city limits answers to both. A building in Aurora, Lakewood, or anywhere else in the state answers only to BPC.
Thresholds
The state covers buildings of 50,000 square feet or more. Denver covers buildings of 25,000 square feet or more. So a 30,000 square foot Denver building has an Energize Denver obligation and no state obligation, and a 60,000 square foot Denver building has both.
Deadlines
Energize Denver benchmarking is due June 1. The state report, fees, and survey are due November 1. Denver also requires third party verification of benchmarking data, first due June 1, 2026. The state has no verification requirement.
Targets
Denver sets an interim target for 2028 and a final target for 2032 for most buildings. The state sets a single 2030 target, held through 2050. Under the state statute, a Denver building that meets Energize Denver performance requirements is deemed compliant with the state performance standard. That deeming applies to performance only. The state benchmarking report and the $500 in annual fees are still due.
Penalties
The state's benchmarking penalties are up to $577 for a first violation and $2,300 for each after; its performance penalties start January 1, 2030 at up to $2,300 per 30 days, then $5,800. Denver assesses its own penalties under its ordinance. We do not list Denver's amounts here until we have verified them against the current ordinance text; the Energize Denver Hub is the source.
Common questions
- Do Denver buildings have to comply with both programs?
- Yes. Energize Denver is a city ordinance and Building Performance Colorado is state law. A Denver building of 50,000 square feet or more files with both.
- If I meet Energize Denver's targets, am I done with the state?
- Meeting Energize Denver performance requirements is deemed compliance with the state performance standard, but the state benchmarking report and the state fees are still due every November 1.
- What are the two benchmarking deadlines?
- Energize Denver: June 1. Building Performance Colorado: November 1.