Washington Tier 2 Clean Buildings compliance: Limited Funding Available for Washington Tier 2 Buildings. Apply before it’s gone.
If your building is 20,001 to 50,000 square feet, or multi-family over 20,000 square feet, Washington requires three documents by July 1, 2027. We prepare all three, submit them to Commerce, and claim your incentive for you.
WA's #1 Clean Buildings Filer1
What are Building Performance Standards?
A building performance standard (BPS) is a law that requires existing buildings to measure their energy use and improve it over time, usually by meeting an energy or emissions target by a set deadline.
It goes a step further than a benchmarking law. Benchmarking only asks owners to report how much energy a building uses. A performance standard sets a bar the building is expected to clear. Several states and cities now have one.
Washington's Clean Buildings Performance Standard
Washington's is the Clean Buildings Performance Standard (CBPS), run by the Department of Commerce. It became law in 2019 and was expanded in 2022, with the aim of lowering energy costs and pollution from the state's existing buildings. It sorts buildings into two tiers by size.
Gross square feet, excluding parking.
- Tier 1
- Nonresidential buildings over 50,000 square feet. They must meet an energy performance target or an approved alternative pathway, with reporting deadlines from June 1, 2026 to June 1, 2028 depending on size.
- Tier 2
- Nonresidential buildings over 20,000 and up to 50,000 square feet, plus multi-family buildings over 20,000. Owners must report benchmarking, an Energy Management Plan, and an Operations and Maintenance Program by July 1, 2027. They must also determine an energy use intensity target and report it to Commerce, but do not have to meet it yet. This is the tier we file for.
What is a Tier 2 building?
Your building is Tier 2 if its nonresidential floor area, excluding parking, is over 20,000 and up to 50,000 gross square feet, or if it is multi-family over 20,000 gross square feet.
- Nonresidential means office, retail, warehouse, hotel, motel, dormitory, and similar uses. Their floor areas add together.
- Parking garage area is excluded from the count.
- Nonresidential over 50,000 square feet is Tier 1, with earlier deadlines and a performance target. This site covers Tier 2 only.
- Buildings at or under 20,000 square feet are not covered by the standard today.
If your building is Tier 2, the early adopter incentive is paid first come, first served from a fixed fund, so the earlier you file, the more likely you are to be paid. How the incentive works
Not sure of your gross floor area? Use the checker above with your best estimate, or ask us on the call. We verify square footage as part of the filing.
When is the Tier 2 deadline?
Tier 2 buildings must report to Commerce by July 1, 2027, then every five years after that. Commerce is accepting early filings now.
Benchmarking uses twelve months of whole-building energy data, so gathering it is usually the first step and often the slowest, especially when tenants pay their own utility bills. Early filers also reach the incentive fund first.
Incentives, simplified.
Washington pays Tier 2 owners to comply, through two incentives. Your utility sends the money after Commerce certifies your filing, first come, first served, from a $150 million fund. About $138 million remained as of September 2026.
Tier 2 Early Adopter Incentive
$0.30 per square foot of eligible floor area (excluding parking, unconditioned, and semi-conditioned space), for owners who benchmark the building's energy use intensity in ENERGY STAR Portfolio Manager, determine and report its energy use intensity target, and put an Energy Management Plan and an Operations and Maintenance Program in place.
Because the fund is first come, first served, a building that files in 2026 is more likely to be paid than one that files in June 2027. Payment may be reduced or delayed.
Anti-Displacement Agreement
Multi-family building owners who sign an Anti-Displacement Agreement can receive up to $0.75 per square foot, though never more than the estimated cost of compliance.
Multi-family buildings only. Every other Tier 2 building receives the base $0.30 per square foot.
If the estimated cost of compliance comes in below the base rate, Commerce pays the base $0.30 instead.
What is the penalty for missing Tier 2?
If a Tier 2 owner doesn't report on time, Commerce can issue penalties by legal notice, stepping them up the longer the building stays out of compliance. The total is capped at $0.30 per square foot.
On a 30,000 square foot building that is up to $9,000, the same amount the building would have been paid for filing early.
File late: pay up to $0.30 per sq ft
Same number, opposite direction.
Three documents. One submission.
Step 1: Benchmarking
Twelve months of whole-building energy data entered in ENERGY STAR Portfolio Manager and shared with Commerce. We set up the account, pull utility data, and verify the square footage.
Commerce expects: A Portfolio Manager report covering the prior calendar year.
Step 2: Energy Management Plan
A written plan that names who is responsible for the building's energy use and how performance is tracked, comparing the energy use intensity benchmarked in ENERGY STAR Portfolio Manager each year against the building's energy use intensity target. Tier 2 buildings must determine that target, on Commerce's Form B or, if the building can't develop one that way, as the national median EUI for the property type, and report it to Commerce, but do not have to meet it yet.
Commerce expects: The plan, signed, with the EUI target stated, reported through Commerce's Energy Management Plan Reporting Tool.
Step 3: Operations and Maintenance Program
A schedule of inspection and maintenance for the building's energy systems, built from Commerce's O&M tool and your actual equipment list.
Commerce expects: The O&M program, reported through Commerce's Operations and Maintenance Reporting Tool, and evidence it is in use.
Finally: Submitted, incentive claimed
We submit all three through the Clean Buildings Portal and file the incentive application at the same time. Most buildings take six to ten weeks from the first call to submission.
You can file without us.
Commerce publishes a free EMP template, an O&M development tool, and a benchmarking guide. The template and development tool are optional aids; the EMP and O&M Reporting Tools are required for filing. Portfolio Manager is free. If you have someone who can commit a few days, read utility bills, and is comfortable with a spreadsheet, you can do this. Don't skip the energy use intensity target: Tier 2 buildings don't have to meet it yet, but you still have to determine it and report it to Commerce on Form B.
Resources
- Tier 2 compliance page, with the optional EMP template and O&M development tool, the required EMP and O&M Reporting Tools, and the benchmarking guide
- ENERGY STAR Portfolio Manager, free
- Clean Buildings Portal
Would rather not take it on yourself? We prepare and file all three documents for you. Book a free call and we'll tell you straight whether you need us or can do it yourself.
What does Tier 2 filing cost?
Standard filing
$5,500* single building
If your building qualifies for and receives the Early Adopter Incentive, your incentive will exceed our service fee. Guaranteed.**
Pilotlight handles the heavy lifting, from evaluating compliance requirements and preparing documentation to submitting your filing and incentive application.
You achieve compliance, recover the cost of our standard service through the incentive, and keep the difference.
Incentive funding is limited and time-sensitive. Don't miss your opportunity.
* Standard pricing assumes required building and utility records are readily available. Additional fees may apply for missing records, extensive research, or unusually complex filings. Any additional cost will be communicated before work proceeds.
How you pay
- 50%Due at contract signing, after your free assessment
- 50%Due when we submit your application to Commerce
Portfolios
Owners of more than one Tier 2 building get a discounted per-building rate, quoted for the portfolio.
Tell us how many buildings you have on the assessment call and we will quote the portfolio.
What is included
- ENERGY STAR Portfolio Manager setup, utility data, and square footage verification
- Energy use intensity benchmarked in ENERGY STAR Portfolio Manager
- Energy Management Plan, reported through Commerce's reporting tool
- Operations and Maintenance Program built from your equipment list
- Submission through the Clean Buildings Portal
- Tier 2 Early Adopter Incentive application, filed at the same time
** Our fee applies regardless of incentive approval or payment, as it covers the compliance filing itself.
Washington Tier 2 questions, answered.
Coverage
Which buildings are Tier 2 under Washington's Clean Buildings Performance Standard?
A building is Tier 2 when the combined floor area of its nonresidential space, counting hotel, motel, and dormitory space as nonresidential, is over 20,000 and at most 50,000 gross square feet, or if it is a multi-family residential building over 20,000 gross square feet. Parking garage area is excluded. Nonresidential buildings over 50,000 square feet are Tier 1.
Does parking garage area count toward Tier 2 square footage?
No. Washington's Clean Buildings Performance Standard excludes parking garage area when it measures a building's gross floor area, for both Tier 1 and Tier 2.
Are any Tier 2 buildings exempt from the Clean Buildings Performance Standard?
The standard doesn't apply to federal buildings or to buildings owned by federally recognized tribes. Any other Tier 2 building can be exempted only if it meets one of Commerce's eight criteria: no certificate of occupancy, no physical occupancy, unconditioned or semi-heated space, manufacturing or industrial use, agricultural use, demolition, financial hardship, or national security. The first four count when, alone or together, they cover more than half the building's floor area. Owners apply one building at a time through the Clean Buildings Portal, up to two years before the compliance date and no later than six months before it, and an approved exemption covers the current five-year cycle only.
Deadlines
When is the Washington Clean Buildings Tier 2 deadline?
The first Tier 2 report is due to the Washington State Department of Commerce on July 1, 2027. After that, owners report again every five years. Owners can file early, and early filers reach the incentive fund first.
Can I get an extension on the Tier 2 deadline?
Yes. Owners can ask Commerce for two more years through the Clean Buildings Portal. The request window opens six months ahead of the compliance date and closes six months after it. The application needs supporting documentation and must show a qualifying reason, such as circumstances beyond the owner's control.
How long does Tier 2 compliance take?
Six to ten weeks from the first call to submission for most buildings we file. The longest step is usually gathering twelve months of utility data to benchmark the building in ENERGY STAR Portfolio Manager.
Requirements
What does Tier 2 compliance require?
Tier 2 owners need three things: the building's energy use benchmarked in ENERGY STAR Portfolio Manager, an Energy Management Plan that is written and in use, and an Operations and Maintenance Program that is written and in use. They must also determine the building's energy use intensity target and report it to Commerce on Form B, though they do not have to meet it yet. Owners file everything in the Clean Buildings Portal.
Do Tier 2 buildings have to meet an energy target?
No. Tier 2 buildings must determine an energy use intensity target and report it to Commerce on Form B, but for now they don't have to meet it. Tier 1 buildings, over 50,000 square feet, must meet a target or an approved alternative pathway.
Do I need a qualified energy manager for Tier 2?
Yes. Every Tier 2 filing needs a qualified energy manager. Commerce runs a free training course for the role through the Smart Buildings Center.
How do I submit Tier 2 compliance to Commerce?
Through the Clean Buildings Portal, Commerce's online system for compliance, exemption, and extension applications. The Tier 2 Early Adopter Incentive application is filed in the same portal.
Can I comply with Tier 2 on my own?
Yes. Commerce publishes a free Energy Management Plan template and Operations and Maintenance development tool, both optional, though filing requires Commerce's Energy Management Plan Reporting Tool and Operations and Maintenance Reporting Tool. ENERGY STAR Portfolio Manager, where the building's energy use intensity is benchmarked, is free. Owners who file on their own still have to determine the building's energy use intensity target and report it to Commerce on Form B.
Incentives
How much is the Tier 2 Early Adopter Incentive?
Commerce's Tier 2 Early Adopter Incentive pays up to $0.30 per square foot of eligible floor area, which excludes parking, unconditioned, and semi-conditioned space. Multi-family building owners who sign an Anti-Displacement Agreement can receive up to $0.75 per square foot, though never more than the estimated cost of compliance; this rate is for multi-family buildings only. A building with 30,000 square feet of eligible floor area can earn up to $9,000 at the base rate. Payment may be reduced or delayed.
Is Tier 2 incentive money still available?
Yes. Over $138 million of the program's $150 million remained as of September 24, 2026. Incentives are paid first come, first served, so owners who file earlier are more likely to be paid.
Who pays the Tier 2 incentive?
The building owner's participating utility pays the incentive directly to the owner, after Commerce reviews and approves the compliance and incentive applications.
Penalties
What is the penalty for missing the Tier 2 deadline?
Commerce can assess administrative penalties of up to $0.30 per square foot on Tier 2 owners who fail to report, issued progressively by legal notice. On a 30,000 square foot building the maximum is $9,000, the same amount the building could have earned by filing early.
About us
How much does Easy BPS charge to file Tier 2 compliance?
Easy BPS charges $5,500 for a standard filing on a single Tier 2 building. Half is due at contract signing and half when the application is submitted to Commerce. The Tier 2 Early Adopter Incentive is calculated at a base rate of $0.30 per square foot of eligible floor area, which excludes parking, unconditioned, and semi-conditioned space, so it exceeds the fee when a building has more than 18,333 square feet of eligible space. The utility that pays the incentive can pay less than the calculated amount, or nothing, if it has used up the tax credit that funds the payment. Standard pricing assumes the building and utility records are readily available; missing records, extensive research, or unusually complex filings can cost more, and any additional cost is communicated before work proceeds. Owners of more than one Tier 2 building get a discounted per-building rate. The fee applies regardless of incentive approval or payment, because it covers the compliance filing itself; even without the incentive, filing avoids a penalty of up to $0.30 per square foot.
Does Easy BPS offer a free assessment?
Yes. Every engagement starts with a free assessment. Easy BPS confirms whether the building is Tier 2, estimates the incentive it can earn, and says plainly whether the owner needs help. There is no charge and no obligation to sign.
Is Easy BPS part of the Washington State Department of Commerce?
No. Easy BPS is an independent compliance service operated by Pilotlight in Seattle, and is not affiliated with Commerce or any utility. Every requirement and figure on this site links to Commerce, which is the only authority on the standard.
Answers checked against Commerce on .