Skip to main content

Home / Local laws / LL88

NYC local law · since 2009

LL88

Local law

DOB

Local Law 88: lighting & sub-metering compliance.

Updated July 2026

LL88 required lighting upgrades and tenant sub-meters in NYC buildings by Jan 1, 2025. What compliance means now, penalties if you missed it, and monitoring.

20,000+ NYC buildings covered

— Monitor this automatically

ViolationWatch tracks Local Law 88 status and deadlines automatically per-building. 60/30/7-day reminders routed to whoever owns the filing. Included in every plan.

60 day

30 day

7 day

Applies to
Buildings over 25,000 sq ft with tenant spaces over 10K sq ft
Cycle / deadline
One-time obligation — compliance deadline was 2025
Qualified by
Licensed electrician + Registered Design Professional
Penalty for missing
$1,500 per year for missed compliance

— The 30-second answer

Local Law 88 required NYC buildings over 25,000 square feet to upgrade lighting to current energy code and install electrical sub-meters in large tenant spaces by January 1, 2025. The deadline has passed — buildings without a compliance report on file face penalties and should file as soon as the work is complete.

— Covered buildings

Is my building on the LL88 covered buildings list?

There is no separate LL88 list to look yourself up on. LL88 applies to the same universe of buildings as LL84 benchmarking, so the LL84 covered buildings list is the practical reference — if you are benchmarking, you are almost certainly covered by LL88 as well.

Covered

Over 25,000 sq ft

Single buildings over 25,000 gross square feet, and tax lots with multiple buildings totalling more than 100,000 square feet.

Lighting applies to

Non-residential space

The lighting upgrade covers the non-residential portions of a covered building. Dwelling units themselves are out of scope.

Sub-metering applies to

Tenant spaces 10K+

Every tenant space over 10,000 square feet needs its own electrical sub-meter, with monthly consumption statements provided to the tenant.

The LL88 deadline has passed. The obligation has not.

Compliance was due January 1, 2025. That date is behind us, which changes the question from "when do I file" to "what happens now" — and the answer is that LL88 is an open, ongoing obligation with an accruing penalty, not a missed window that closed.

If you filed before January 1, 2025

You are done. LL88 is a one-time obligation — there is no recurring cycle and no renewal. Keep the filed certification with the building's compliance records; it will be asked for in diligence on any sale or refinance.

If the work is done but nothing is on file

This is the most common position, and the easiest to fix. The building is not compliant until the certification is filed — the physical work does not count on its own. File now and the exposure stops accruing.

If the work is not done

Complete the lighting upgrade and install the sub-meters, then file. Penalty exposure runs at $1,500 per year until the certification is on record, and the gap shows up as an open item against the property in the meantime.

The LL88 report

What goes in the filing, and who signs it.

The LL88 report is a certification, not a study. It states that both halves of the obligation are complete, and it must be signed by a registered design professional or a licensed electrician — the same professional who oversaw the work is the usual choice.

Half one — lighting

Confirmation that lighting in the covered non-residential areas meets the current NYC Energy Conservation Code, including fixtures, controls and occupancy sensing.

Half two — sub-metering

Confirmation that every qualifying tenant space has a sub-meter installed and that tenants receive monthly statements of their own electrical consumption.

A partial filing is not a filing. Buildings that upgraded lighting and skipped the sub-meters — or metered the space and never certified — carry the same exposure as buildings that did nothing at all.

Classifications & outcomes

The three results of a LL88 review.

COMPLIANT

Lighting upgraded, sub-meters installed, cert of compliance filed with DOB.

PARTIAL

Lighting done, sub-metering missing. Still exposed to LL88 penalty until cert filed.

NON-COMPLIANT

No cert on file. $1,500/year penalty + DOB violation on record.

The cost of missing

LL88 penalties compound fast.

LL88 enforcement is largely administrative — DOB runs compliance sweeps based on filing status, not complaint volume. Once you're flagged, penalties apply until the underlying filing or condition is resolved.

Missed filing

$1,500 per year for missed compliance

Compliance failure

N/A

Deadline pattern: Original deadline: January 1, 2025. Ongoing enforcement thereafter.

What we monitor

How ViolationWatch tracks Local Law 88 for every building in your portfolio.

01

Auto-mapping per BIN

We resolve every building you add to its BIN, BBL, block, and lot — and check whether LL88 applies automatically.

02

Deadline calendar

One-time obligation — compliance deadline was 2025 is computed and calendared per building. Visible in the dashboard; reminders fire at 60, 30, and 7 days.

03

Filing status

We surface any existing LL88 filings on record, so you know before you start whether the building is current, due, or already in arrears.

04

Routing by role

LL88 reminders go to whoever owns compliance filings at your portfolio — property manager, asset manager, legal counsel, or the super.

05

Related violations

LL88 non-compliance commonly generates downstream DOB violations. When one appears, we correlate it to the underlying law automatically.

06

Portfolio rollup

See your entire portfolio's LL88 state at once — compliant vs due vs overdue — in a single dashboard view.

— LL88 questions, answered

What owners ask about Local Law 88.

What does LL88 compliance require?

Two things: upgrading the building's lighting systems to meet the NYC Energy Conservation Code, and installing electrical sub-meters in every tenant space over 10,000 square feet — then filing a report by a registered design professional or licensed electrician confirming both.

What happens if I missed the LL88 deadline?

The obligation doesn't lapse — complete the lighting upgrade and sub-metering now and file the compliance report. Until it's on file, the building carries ongoing penalty exposure and the gap surfaces in due diligence on any sale or refinance.

Which buildings does Local Law 88 cover?

Buildings over 25,000 gross square feet, the same universe as LL97 and LL84 benchmarking. Residential spaces are exempt from the sub-metering requirement; the lighting upgrade applies to the non-residential portions of covered buildings.

— Your Local Law 88 deadline is coming

Track it once. Never miss it.

Add your building. ViolationWatch handles the rest — LL88 plus 7 other local laws plus 10 enforcement agencies. $9 per building per month.