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Aug. 6, 2026 · Written by Thomas T. Jarloev

NYC Local Law 87: retro-commissioning is a legal requirement - here's how to manage it

RCx documentation on a New York City building for Local Law 87

If your building is over 50,000 square feet in New York City, retro-commissioning is not optional. It is the law.

What Local Law 87 requires

NYC Local Law 87 requires owners of buildings over 50,000 square feet, or two or more buildings on the same tax lot totaling over 100,000 square feet, to complete an energy audit and a retro-commissioning study once every ten years. The results get filed in an Energy Efficiency Report with the Department of Buildings.

The filing year is not the same for everyone. It is set by the last digit of the building's tax block number, so two buildings on the same block can be due in different years. Missing the deadline is a Class 2 violation, with fines starting at 3,000 dollars for the first year and 5,000 dollars for every year after.

Retro-commissioning under LL87 is judged against Current Facility Requirements rather than the original Owner's Project Requirements, since the building's systems have been running for years and its actual use has likely drifted from what was originally designed.

The type of work this creates

An LL87 retro-commissioning study is not paperwork about new construction. It is proof that existing systems, many of them undocumented, still perform the way they are supposed to. That proof comes from Functional Performance Tests, Prefunctional Checks, sensor calibration verifications, and field observations logged on every walkthrough - all tied back to the right asset and ready to support the Energy Efficiency Report.

For a Cx team taking on more LL87 work, this is where the admin load actually lives. Every test, every calibration check, every observation needs to be documented in a way that holds up if the Department of Buildings comes asking.

Source: NYC Department of Buildings, Local Law 87 of 2009. For full requirements, visit nyc.gov.

How CxPlanner manages it

CxPlanner gives the RCx team one place to build and run PFCs and FPTs instead of a folder of Word templates and spreadsheets. CxAI generates the test script for the test type you need - PFC, FPT, sensor calibration verification - drawing on CxPlanner's template library or your own project documentation, so the team is not writing the same checklist from scratch on every LL87 project.

Field observations get logged from a phone on site, photo included, and tied straight to the asset instead of sitting in a notebook until someone transcribes it back at the office. When it is time to put the Energy Efficiency Report together, the documentation is already structured and in one place, not scattered across five different files.


If NYC Local Law 87 is showing up more often in your pipeline, see how CxPlanner handles the documentation side of an RCx project. Book a demo and we'll walk through PFCs, FPTs, and field capture with your own project setup.

Book a demo with Thomas