Local Law 88 · Lighting & Submetering
The LL88 Deadline Passed. The Fines Didn't.
Lighting upgrades, tenant submetering, and the report a licensed master electrician has to file. If your building is covered and the filing never happened, the penalties have been accruing since 2025.
Sound familiar?
You inherited the building, or the portfolio, or just the folder. Somewhere in it there may be a Local Law 88 filing from 2025. Or there may not be. Nobody has gone looking, because nothing has forced anyone to look, and this kind of penalty does not arrive with a phone call.
The fine is small enough to ignore and annual enough to add up.
01 / What happened
Two deadlines, both behind us.
The Local Law 88 (LL88) work deadline was January 1, 2025, and the compliance report was due to DOB by May 1, 2025. Buildings that still had not demonstrated compliance appeared on DOB's 2026 covered buildings list with a new filing deadline of May 1, 2026 and a grace period that ended June 30, 2026. Both cycles have passed.
Buildings that have not filed accrue $1,500 annually for a missing lighting upgrade report and $1,500 annually for a missing submeter report. Where a report has been filed but submeters are not installed in all covered tenant spaces, the fine is $500 annually for each space still without one. Those amounts repeat every year until the building demonstrates compliance.
A building that has filed and demonstrated compliance does not have to file again. The question is whether yours has.
Regulatory status verified against DOB guidance, August 2026.
02 / Two ways to be out of compliance
There are two ways to be out of compliance, and one of them surprises people.
The work was never done.
The lighting was never brought up to the Energy Conservation Code, or the submeters were never installed, or both. This is a project: audit, upgrade, install, then file.
The work was done and the report was never filed.
The building upgraded its lighting. Somebody installed submeters. And the filing that closes it out never happened, so on paper the building is still out of compliance and the fines are still running.
The second case is more common than owners expect, and it is the cheaper problem by a wide margin. There is nothing to build. There is a report to file, and it has to be filed by someone licensed to file it.
03 / Coverage
Is your building covered?
Local Law 88 applies to buildings over 25,000 square feet, to multiple buildings on a single tax lot that together exceed 100,000 square feet, and to two or more condominium buildings under the same board of managers that together exceed 100,000 square feet.
Lighting. Covered buildings upgrade lighting systems to meet the NYC Energy Conservation Code. In residential buildings that means common areas: lobbies, hallways, basements, service areas, mechanical rooms, and laundry rooms.
Submetering. Covered tenant spaces above 5,000 gross square feet require electrical submeters, with usage information provided to tenants.
If you are not sure whether your building is covered, that is the first thing we check, and we check it free.
The report cannot be filed by just anyone.
Local Law 88 compliance has to be certified by a registered design professional, a licensed master electrician, or a licensed special electrician. That is a short list, and we are on it. We do the lighting work, we install the submeters, and we file the report that closes the file.
The job is done when the file is closed.
04 / What we handle
Audit, upgrade, install, file.
LL88 status check
We confirm whether your building is covered and whether anything has been filed. Free, within one business day.
Lighting audit
A walk of common areas and covered spaces against current Energy Conservation Code requirements, with a written scope of what needs upgrading.
Lighting upgrades
LED conversion, controls, occupancy sensing, and the code-compliant fixtures the law requires. We were doing fluorescent and ballast retrofits long before LL88 made them mandatory. Phased across a portfolio where that suits your budget.
Tenant submetering
Submeter installation in covered tenant spaces, wired and commissioned.
The report and the filing
Prepared and filed under our master license. You get the confirmation, not a to-do list.
Permits and DOB NOW
Handled in-house.
05 / Beyond the fine
Closing the fine is the smallest benefit.
Lighting upgrades cut electrical load directly. That shows up in your Local Law 97 (LL97) emissions number without touching the mechanical plant, which makes LL88 one of the few compliance projects that pays into two obligations at once.
Submetering does something else worth having. It shows which parts of the building drive consumption, which turns a building-wide emissions problem into a list of specific, addressable line items. You stop guessing about where the load is.
For most portfolios this is the fastest compliance work to scope and complete, and it is a reasonable place to start before the larger electrification conversation.
06 / The LL97 connection
You can't claim LL97 good faith with LL88 open.
Buildings that cannot meet their LL97 emissions limits can pursue penalty mitigation through DOB's good faith efforts pathway. That pathway has three threshold requirements: the annual emissions report, LL84 benchmarking, and LL88 compliance, meaning both the lighting upgrades under Article 310 and the submetering under Article 311.
So a building carrying an open LL88 obligation is not only accruing LL88 fines. It does not qualify for the pathway that keeps LL97 penalties from compounding.
Relief is also not permanent. Where DOB grants mitigation based on a good faith claim and the building does not follow through on what it committed to, previously mitigated penalties can be reinstated.
LL88 is the smallest item on the compliance list and the gate to the largest.
07 / Start here
Start with the question you can't answer from your desk.
Send us the address. We will tell you:
- Whether the building appears on DOB's current covered buildings list
- Whether the building is covered by LL88
- Whether a lighting report or submeter report has been filed
- What is still open, and what closing it involves
Free, back within one business day.
If the filing is all that is missing, that is a short conversation and a small scope. If work is needed, you get a written scope and a price before anything starts.
Not ready for an assessment?
One address. One answer.
Find out where your building stands on LL88, and what it takes to close it.