Colorado's Building Performance Standard (HB 21-1286) is one of the most ambitious in the US — with statewide benchmarking requirements already in effect and EUI performance targets on the way.
Colorado enacted House Bill 21-1286 in 2021, establishing one of the nation's first statewide building performance standards for commercial and multifamily buildings. The law is administered by the Colorado Energy Office (CEO) and sets a framework for mandatory benchmarking and eventual energy performance targets designed to reduce greenhouse gas emissions from the state's largest buildings.
The program applies to commercial and multifamily buildings larger than 50,000 square feet statewide. The first major milestone — benchmarking — required covered building owners to register with the Colorado Energy Office and submit energy use data through ENERGY STAR Portfolio Manager by December 1, 2025. If your building missed this deadline, it is already out of compliance and remediation steps should begin immediately.
Looking ahead, the Colorado Energy Office is developing performance standards (EUI targets) by building type, with compliance deadlines beginning in 2026 and extending through the end of the decade. While statewide targets are still being finalized through rulemaking, building owners can begin preparing now by understanding their current Energy Use Intensity, identifying efficiency gaps, and developing a capital improvement roadmap. Meanwhile, buildings located within Denver city limits face a separate, more immediate obligation: the City and County of Denver's Energize Denver program, which has established specific EUI targets and compliance deadlines with active penalties for non-compliance.
Colorado commercial buildings may be subject to one or both programs. Denver buildings must navigate both the statewide standard and Energize Denver.
Whether you missed the 2025 deadline or are catching up now, these three steps define the benchmarking process under HB 21-1286.
Create an account with the Colorado Energy Office and register your covered building(s) under the BPS program. You will need your building's address, square footage, primary use type, and owner contact information.
Set up your building in EPA's ENERGY STAR Portfolio Manager and enter at least 12 consecutive months of energy consumption data for all fuel types: electricity, natural gas, and any other fuels used. Work with your utility to obtain automated data sharing where available.
Generate your benchmarking report from Portfolio Manager and submit it to the Colorado Energy Office through the required reporting channel by the applicable deadline. Retain documentation of your submission for your records and prepare for future annual reporting cycles.
Denver has established specific Energy Use Intensity targets for buildings over 25,000 SF. The 2028 targets represent an interim compliance milestone (per April 2025 rules update); the 2030 and 2032 targets reflect the final performance standards.
| Building Type | 2028 EUI Target (kBtu/SF/yr) | 2030/2032 EUI Target (kBtu/SF/yr) |
|---|---|---|
| Office | 55 | 44 |
| Retail | 60 | 48 |
| Hotel / Lodging | 80 | 65 |
| Multifamily Residential | 55 | 44 |
| Healthcare | 200 | 165 |
* Energize Denver targets. Statewide Colorado BPS performance targets are still under development through the Colorado Energy Office rulemaking process and are not yet finalized.
Both the statewide program and Energize Denver carry enforcement mechanisms. Denver's penalties are already defined and substantial for large buildings.
Buildings in Denver that fail to meet their 2028 or 2030/2032 EUI targets face annual fines based on the total kBtu they exceed their target. A building barely missing its target pays minimal penalties; a building far below it pays substantially more. Penalties apply each year the building remains out of compliance, meaning costs compound over time.
The Colorado Energy Office is in active rulemaking to establish penalty provisions for statewide BPS non-compliance, including failure to benchmark by the December 2025 deadline. Building owners should not interpret the absence of a final number as an absence of risk.
From setting up your first benchmarking account to developing a multi-year compliance roadmap, we handle the full process — remotely, efficiently, and with CEM-certified expertise.
We set up your ENERGY STAR Portfolio Manager account, collect 12 months of utility data for all fuel types, calculate your EUI, and submit your benchmarking report to meet Colorado Energy Office requirements. We handle the paperwork so you don't have to.
Energy Benchmarking Service ›We compare your current EUI against Colorado BPS statewide targets and Energize Denver thresholds, identify the performance gap, and provide a prioritized list of energy conservation measures with estimated savings and cost ranges to close that gap on your timeline.
BPS Compliance Service ›We develop a multi-year compliance roadmap that sequences capital improvements, identifies utility incentive programs, and ensures your building reaches its 2028 interim and 2030/2032 EUI targets on budget. We also document your compliance plan to demonstrate good-faith effort to regulators.
BPS Compliance Service ›Answers to the questions commercial building owners ask most frequently about HB 21-1286 and Energize Denver compliance.
Whether you missed the benchmarking deadline, need an EUI gap analysis, or want a compliance roadmap for 2028, 2030, and 2032 — Green Check Solutions can help. CEM-certified, remote-capable, and fully focused on building performance compliance.