Oregon's Building Performance Standard requires commercial buildings over 20,000 SF to benchmark energy use and — eventually — meet performance targets. Here's what you need to know.
Oregon enacted its Building Performance Standard (BPS) through the Oregon Department of Energy (ODOE), establishing one of the Pacific Northwest's first statewide mandates for commercial building energy performance. The program applies to privately owned commercial buildings greater than 20,000 square feet, covering a much broader segment of the commercial building stock than Washington's comparable program.
The Oregon BPS is currently in its rollout and rulemaking phase. The first concrete milestone is benchmarking registration beginning July 1, 2026, when covered building owners must register with ODOE and begin reporting energy use through ENERGY STAR Portfolio Manager. This initial data collection phase will establish the baseline that informs Oregon's eventual performance targets.
Performance compliance requirements — meaning hard EUI targets your building must meet — are expected to follow the benchmarking phase, likely beginning in 2028 or later as the state completes rulemaking. While the specific targets have not yet been set, Oregon's framework closely mirrors Washington's Clean Buildings Performance Standard, and building owners who benchmark now will be better positioned when compliance deadlines arrive. Because Oregon's program is actively evolving, owners should confirm the latest requirements directly with ODOE.
Oregon's BPS is phasing in requirements over time. Below is the current schedule as of early 2026. Confirm deadlines with ODOE as rulemaking continues.
| Requirement | Threshold | Deadline | Status |
|---|---|---|---|
| Benchmarking Registration | Buildings >20,000 SF | July 1, 2026 | Confirmed |
| First Benchmarking Report | Buildings >20,000 SF | 2028–2030 (Tier 1, phased by size) | Confirmed |
| Performance Compliance | In development — ODOE rulemaking | 2028+ (targets in development) | Rulemaking in Progress |
Benchmarking is the foundation of Oregon's BPS. It establishes your building's Energy Use Intensity (EUI) — the metric used to measure and compare energy performance. Here are the three core steps.
Register your building in EPA's ENERGY STAR Portfolio Manager platform, the standard tool used for commercial building energy benchmarking. You will need to enter your building's basic characteristics: gross square footage, occupancy type, number of occupants, operating hours, and other property details that affect energy use. If you own multiple covered buildings, each must be entered as a separate property.
Input at least 12 consecutive months of energy consumption data for all fuel types: electricity, natural gas, fuel oil, steam, and any other sources used by the building. Data must cover the entire building, including tenant spaces where the building owner pays utility costs, as well as individually metered tenant spaces where data can be obtained. Portfolio Manager will calculate your site EUI and source EUI automatically once data is entered.
Once your data is entered and verified, submit your benchmarking report to the Oregon Department of Energy through their designated reporting portal. ODOE will provide specific submission instructions and deadlines through their rulemaking process. Your submitted report establishes your building's official energy performance baseline for the program.
Both states have building performance standards, but the programs differ in key ways. If you own commercial buildings in both states, here is what you need to understand.
| Category | Oregon BPS | Washington CBPS |
|---|---|---|
| Building Threshold | Greater than 20,000 SF | Greater than 50,000 SF |
| Benchmarking Deadline | July 1, 2026 | Already required (ongoing) |
| Performance Compliance | 2028+ (ODOE rulemaking in progress) | 2026–2028 (by building size) |
| EUI Targets | Not yet set | Established by building type |
| Penalties | Up to $5,000 + $1.00/SF/yr (non-report); $1,500 + $0.20/SF/yr (non-compliant). No Tier 2 penalties. | $5,000 + $1.00/SF/yr |
| Program Status | Active — penalty rules finalized Aug 2025 | Fully enacted, targets in effect |
| Administering Agency | Oregon Dept. of Energy (ODOE) | WA Dept. of Commerce |
The most significant practical difference is timing. Washington's program is already fully enacted with hard deadlines and enforceable penalties. Oregon is still building toward that point. However, Oregon's lower 20,000 SF threshold means that many buildings exempt from Washington's program will be covered in Oregon — making Oregon BPS relevant to a larger portion of commercial building owners in the state.
If you own buildings in both states, our BPS compliance services cover both programs under a single engagement, minimizing duplication of effort and data collection.
Most building owners wait until deadlines are finalized before taking action. That strategy has real costs. Here is why acting during the rulemaking phase is the smarter move:
Oregon's program will eventually look like Washington's: mandatory targets, reporting requirements, and financial penalties for non-compliance. The only question is how prepared you are when that day arrives. The cost of getting benchmarked today is a small fraction of the cost of emergency compliance work when deadlines are imminent.
We provide end-to-end Oregon BPS support — from initial benchmarking setup through gap analysis and compliance strategy as the program matures. CEM-certified, remote delivery, no disruption to operations.
We set up your ENERGY STAR Portfolio Manager account, collect and enter 12 months of utility data across all fuel types, verify your EUI calculation, and prepare your benchmarking report for ODOE submission. We handle the data collection process so you do not have to track down bills or navigate utility portals.
Energy Benchmarking Services ›Once Oregon finalizes its performance targets, we compare your building's benchmarked EUI against the applicable target for your building type and identify the specific end uses — HVAC, lighting, plug loads, envelope — driving any gap. We quantify improvement opportunities by cost, savings, and timeline so you can make informed capital decisions.
BPS Compliance Services ›We develop a phased compliance roadmap tailored to your building's lease structure, capital budget, and timeline. This includes identifying applicable utility incentive programs (Energy Trust of Oregon, Pacific Power, Portland General Electric) to offset improvement costs, and preparing the documentation ODOE requires for compliance reporting.
BPS Compliance Services ›Answers to the questions we hear most often from Oregon commercial building owners about the state's Building Performance Standard.
The rulemaking phase is the best time to act. Get benchmarked now, understand your building's current energy performance, and be ready when ODOE's reporting deadlines arrive.
