LL87 energy audits are due December 31. Your managing agent needs no license to file them.

Local Law 87 of 2009 requires buildings of 50,000 square feet or more to conduct a mechanical-systems energy audit and retro-commissioning study every ten years, then file the results with the Department of Buildings as an Energy Efficiency Report. The ten-year cycle is indexed to the last digit of the tax block number in which the building sits. For the current cycle, buildings in the block-6 cohort — one-tenth of all LL87-covered buildings — owe that filing to DOB by December 31, 2026. A first-year failure carries a $3,000 civil penalty under Administrative Code § 28-308.5. A second-year failure adds $5,000 more. In most large condos and co-ops, the person responsible for driving the process from auditor selection to final submission is the managing agent. There is no state license that agent is required to hold, no disciplinary board to receive a complaint, and no credentials at risk if the filing is late or the audit is cursory.

What Local Law 87 requires

Local Law 87 is one of three statutes in the Greener, Greater Buildings Plan enacted by the Bloomberg administration in 2009. It applies to any building — or any set of buildings on a single lot — with 50,000 or more square feet of gross floor area. That threshold captures most large NYC condominium complexes and cooperative apartment buildings.

Every covered building must satisfy two requirements every ten years. First, it must hire a qualified energy auditor to inspect the mechanical systems — heating, cooling, ventilation, lighting, and building envelope — and produce a written report identifying energy conservation measures with estimated payback periods. Second, it must undergo retro-commissioning: a field verification that existing mechanical equipment is operating according to its original design intent. Both findings go into the Energy Efficiency Report, which the building's owner of record submits to DOB.

Compliance is not self-certifying. DOB reviews submissions and can issue violations for late filing, incomplete filings, or EERs that do not meet the technical standards in the administrative rules. The energy auditor must hold specific professional credentials — a licensed engineer or architect, or a Certified Energy Auditor with additional experience. An unlicensed person cannot sign the audit portion. The managing agent does not sign the EER. But in practice it is the managing agent who selects the auditor, manages the site visit schedule, assembles the retro-commissioning field results, reviews the draft EER, and certifies to the board that the submission is complete.

Your building's place in the cycle

The ten-year block-digit schedule was written into the law in 2009 and has not changed. The last digit of the tax block number determines the compliance year. Block numbers ending in 6 entered their current cycle in 2016, which means the filing window closes December 31, 2026.

DOB publishes the compliance schedule on its LL87 page. There is no automatic extension process. A building that misses December 31 enters violation status, and DOB has historically accepted late EERs — but a late submission does not eliminate the first-year penalty notice. It stops further accrual.

Boards can look up their building's tax block number through the Department of Finance's ACRIS or property search tool; the block number also appears on every property tax bill. For large condominium buildings, the block number is typically the same across all units in the complex — it identifies the lot, not the individual apartment. A building with a block number ending in 6 is in the current cohort, regardless of when the board first became aware of it.

Who controls the filing

At most large NYC condos and co-ops, the flow of LL87 compliance work runs through the managing agent. The agent selects the energy auditor, schedules site access for the mechanical inspection, coordinates with building facilities staff on the retro-commissioning field checks, reviews the draft EER, and presents the completed submission to the board for sign-off before filing.

The selection of the auditor is a material decision. An energy auditor who identifies a long list of mechanical deficiencies — a boiler operating at 60 percent of rated efficiency, an air-handling unit with stuck economizer dampers — is recommending work the building must then budget for. An auditor whose findings are systematically thin, clearing systems that are underperforming, produces a document that satisfies the legal requirement while understating the building's real condition. The board rarely has independent means to evaluate which outcome it received.

In buildings managed by large management companies, the auditor is often part of a vendor roster the company has assembled over years of client relationships. The company earns no disclosed fee for placing the vendor. The arrangement is entirely lawful. But the board's ability to evaluate whether the audit it paid for was genuinely independent of the management company's interests is constrained by the same information asymmetry that governs every managing agent relationship in New York State.

No license required

New York licenses barbers, cosmetologists, home inspectors, architects, engineers, attorneys, and mortgage loan originators. It does not license managing agents of residential buildings.

Senate Bill S.71, introduced by Senator Brian Kavanagh in every legislative session since 2017, would require managing agents of buildings above a certain size to obtain a license from the Department of State, satisfy a minimum education or experience requirement, and carry errors-and-omissions insurance. A licensed agent would face disciplinary proceedings, including suspension or revocation, for certifying a deficient compliance product. S.71 has not received a committee hearing in ten consecutive sessions. The 2025-2026 legislative session ended June 18, 2026 without a floor vote. No Assembly same-as companion has been introduced.

The practical effect in the LL87 context is direct. If a managing agent selects an auditor whose retro-commissioning findings are materially incomplete — say, a unit ventilator survey that records only three of twelve floors — and the board discovers the deficiency when DOB issues a violation notice two years later, the agent faces no professional licensing consequences. The only remedies available to the board are civil, under the management contract, or contractual termination. Neither path is fast, and neither restores the missed compliance window.

The penalty clock

Administrative Code § 28-308.5 sets the LL87 penalty schedule. A building that does not submit an EER for its applicable cycle year receives a civil penalty notice from DOB. The first year of non-compliance carries a $3,000 penalty. A second-year failure adds $5,000, bringing the two-year total to $8,000.

These amounts are per-building, not per-unit. In a 150-unit condominium, $3,000 is $20 per unit — a rounding error in most common-charge budgets. The penalty schedule creates no strong financial incentive for a managing agent to prioritize a timely, independent filing. The penalty flows to the board; any vendor relationship flows to the agent.

There is also a compounding obligation boards should note. For buildings that are already non-compliant from a prior cycle — block-6 buildings that missed a 2016 filing, for example — the current December 31 deadline does not erase the prior year's record. DOB's violation tracking follows the building's BBL, and a clean EER submission addresses only the current cycle's obligation.

What boards in the block-6 cohort should do now

Industry practitioners who work on LL87 compliance estimate that a complete cycle — auditor engagement, mechanical site inspection, retro-commissioning field work, EER drafting, and DOB filing — takes six to twelve months under normal scheduling conditions. December 31, 2026 is four months from today.

Boards in buildings with tax block numbers ending in 6 that have not received a written status update from their managing agent should place this on the next board meeting agenda. The board should request written confirmation of: (1) the name of the energy auditor engaged and the date of engagement; (2) the scope and completion status of the retro-commissioning field work; and (3) the projected EER submission date. If no auditor has been engaged, the board should request at least two competing bids from auditors who have no referral relationship with the management company.

Boards should also ask whether the selected auditor has any financial relationship with the managing agent or management firm — a referral arrangement, a shared corporate ownership structure, or a revenue-sharing agreement. New York law does not require that disclosure. Prudent governance does, and the question is one the board is entitled to ask in writing and expect an answer to in writing before approving the engagement.

Bottom line.

If your building's tax block number ends in 6, your LL87 Energy Efficiency Report is due at the Department of Buildings by December 31, 2026, and the compliance clock has been running since January. The managing agent driving that process holds no state license and faces no professional discipline for a deficient submission. S.71 was drafted to change that. It has not moved in ten sessions.

Companion resources: Local Laws 84, 87, 88: The NYC Energy Compliance Bundle — NYC has run a managing agent registry for decades. Still no license required. — Local Law 58 gave co-op boards a 45-day deadline. The bill for buyer financial records did not advance. — Albany 2026: the co-op reform bills that did not advance.