Summary
Details
- Washington (State)
Washington's CBPS applies to owners of covered commercial, institutional, hotel, motel, dormitory, and multifamily residential buildings in Washington. Covered buildings are divided into:
- Tier 1: Generally non-residential buildings exceeding 50,000 square feet.
- Tier 2: Buildings between 20,000 and 50,000 square feet, together with multifamily residential buildings over 20,000 square feet.
Deep dive
📩 Stay ahead of climate regulation and reporting shifts
Regulatory updates, reporting standards, and new climate software — distilled into one concise weekly brief for decision-makers.
Thanks for signing up. Please check your inbox to confirm your subscription.
Practical updates. Once per week.
Overview
Buildings account for a significant share of Washington's energy consumption and greenhouse gas emissions. To improve the performance of the existing building stock, the state enacted the Clean Buildings Performance Standard through Engrossed Third Substitute House Bill (E3SHB) 1257 in 2019. Rather than imposing direct emissions limits, the program focuses on improving energy performance by requiring covered buildings to meet an energy use target or follow an alternative compliance pathway.
The CBPS is based on ASHRAE Standard 100-2018, supplemented by Washington-specific requirements. Building owners must benchmark energy use, implement operational improvements, establish an energy management program, and demonstrate compliance according to phased deadlines based on building size. The program is administered by the Washington State Department of Commerce, which also provides technical assistance, grants, and compliance guidance.
The Washington CBPS is a statewide energy performance standard based primarily on Energy Use Intensity (EUI). It is separate from city-level building performance regulations within the state, such as Seattle's Building Emissions Performance Standard (BEPS), which focuses on greenhouse gas emissions rather than energy use. Although the two programs share the broader goal of improving building performance, they have different compliance metrics, reporting requirements, administering authorities, and deadlines.
Reporting and Compliance Requirements
Compliance revolves around benchmarking, operational improvements, and demonstrating that a building meets the required energy performance standard. Building owners must:
Benchmark energy use using at least 12 consecutive months of energy consumption data.
Develop and implement an Operations & Maintenance (O&M) Program consistent with the CBPS requirements.
Prepare an Energy Management Plan (EMP) documenting how energy performance will be maintained and improved.
Demonstrate compliance by either meeting the building's energy target or completing an approved alternative compliance pathway where eligible.
For Tier 1 buildings, compliance deadlines begin on:
June 1, 2026: Buildings over 220,000 sq. ft.
June 1, 2027: Buildings between 90,001 and 220,000 sq. ft.
June 1, 2028: Buildings between 50,001 and 90,000 sq. ft.
Tier 2 reporting begins in 2027.
Penalties for Non-Compliance
Building owners that fail to comply with the CBPS may be subject to administrative penalties imposed by the Washington State Department of Commerce. Penalties may apply where an owner fails to submit required documentation, does not demonstrate compliance by the applicable deadline, or otherwise fails to satisfy the program's requirements. Commerce also has authority to review submissions, request additional information, and verify compliance through audits.
The legislation authorizes civil penalties of up to US$5,000, plus an additional US$1 per year per gross square foot of floor area for covered buildings that remain out of compliance after notice and an opportunity to correct the violation. Penalties collected under the program support implementation of the Clean Buildings Performance Standard.
Current Status and Outlook
The CBPS is transitioning from preparation to active compliance, with the first Tier 1 reporting deadline arriving in June 2026 for the state's largest buildings. The Department of Commerce continues to refine the program through rulemaking, technical guidance, webinars, grants, and compliance support for building owners. Recent updates have clarified compliance pathways, exemptions, and reporting procedures ahead of the phased implementation schedule.
As compliance expands to smaller buildings over the coming years, the CBPS is expected to become one of Washington's principal building decarbonization policies. By emphasizing improved building operations and energy management rather than fuel switching alone, the program seeks to deliver lasting reductions in both energy consumption and greenhouse gas emissions across the state's existing building stock.
Resources
Cut through the green tape
We don't push agendas. At Net Zero Compare, we cut through the hype and fear to deliver the straightforward facts you need for making informed decisions on green products and services. Whether motivated by compliance, customer demands, or a real passion for the environment, you’re welcome here. We provide reliable information. Why you seek it is not our concern.