Benchmark Colorado

What is Building Performance Colorado?

Colorado's benchmarking and performance standard for buildings of 50,000 square feet or more: who is covered, what is due each year, and what happens in 2030.

Updated 2026-09-19. Facts checked against C.R.S. 25-7-142, Regulation 28, and the Colorado Energy Office. Not legal advice.

Building Performance Colorado, usually shortened to BPC, is the state program that requires large buildings to report their energy use every year and to meet energy or emissions performance targets by 2030. It comes from C.R.S. 25-7-142, created by HB21-1286 in 2021 and amended by HB25-1269 in May 2025, and it is implemented through Regulation 28 of the Air Quality Control Commission. The Colorado Energy Office runs the program and the Air Pollution Control Division at CDPHE enforces it.

Who is covered

Any building with 50,000 square feet or more of gross floor area, unless it falls into one of the exemptions: unconditioned storage, parking structures, and aircraft hangars; buildings where most of the floor area is manufacturing or industrial; residential buildings with one to three units; and certain agricultural buildings. Public buildings must benchmark but pay no fees or penalties, and the performance standard applies to them only after a renovation of $500,000 or more touching at least a quarter of the floor area.

The state publishes a Covered Buildings List with a CO Building ID for each property. If your building is on it, you have a reporting obligation. If it should be on it and is not, the obligation still exists. You can search the list here.

What is due every year

The reporting window runs from July 1 to November 1, starting with 2026. By November 1 a covered building owner submits the prior calendar year of energy data through ENERGY STAR Portfolio Manager into the state BEAM portal, pays the $100 program fee and the $400 Building Decarbonization Enterprise fee, and completes a progress survey. The enterprise fee funds audit support and rebates through the Building Decarbonization Enterprise.

Benchmarking enforcement is active. CDPHE is sending notices, and penalties run up to $577 for a first violation and $2,300 for each violation after that.

The 2030 performance standard

Each covered building must meet a target by 2030, either a site energy use intensity or greenhouse gas intensity target set for its property type, or a standard 29 percent reduction from its 2021 baseline. A 2019 baseline is allowed if 2019 data is filed by November 1, 2027. The 2030 standard then holds through 2050. Compliance is demonstrated in the report filed in 2031, and performance penalties can begin January 1, 2030 at up to $2,300 per 30 days for a first violation and $5,800 per 30 days after that, adjusted for inflation.

A 2026 interim target exists in the rule but the statute lets owners track progress instead, and non-compliance obligations do not apply until 2031 for the 2030 standard. In practice there is no penalty for missing the 2026 interim number.

Relief options and their deadlines

The program has several adjustment paths, most of which require an energy audit to support the request: electing a 2019 baseline by November 1, 2027; changing compliance pathway without documentation by November 1, 2028; requesting an individualized target, target adjustment, or timeline adjustment by December 31, 2029; and a pathway adjustment with documentation by January 31, 2031. Full dates are on the deadlines page.

What about 2040

Nothing is adopted yet. A task force convenes by July 1, 2027, delivers recommendations by July 1, 2028, and a proposal is due by June 1, 2029.

Official sources: Colorado Energy Office program page, HB25-1269, and the BEAM portal.

Common questions

What size building is covered by Building Performance Colorado?
Buildings with 50,000 square feet or more of gross floor area. Unconditioned storage, parking structures, hangars, buildings that are mostly manufacturing or industrial, one to three unit residential buildings, and some agricultural buildings are exempt.
What is due each year?
By November 1: a benchmarking report submitted through ENERGY STAR Portfolio Manager into the BEAM portal, a $100 program fee, a $400 Building Decarbonization Enterprise fee, and a progress survey.
What is the law behind it?
C.R.S. 25-7-142, created by HB21-1286 and amended by HB25-1269 (signed May 20, 2025), implemented through Air Quality Control Commission Regulation 28.

Want someone to handle this for your building?

A Colorado energy consultant will review the deadlines for this building with you. No cost for the first conversation.

More guides