Energize Denver's June 1 Deadline: How to Benchmark, Data Verify, and Avoid the $2,000-a-Year Fine

By June 1, 2026, every Denver building 25,000 sq ft and larger owes two separate things under the Energize Denver Building Performance Policy: a 2025 benchmarking report filed through the Energize Denver portal, and third-party data verification — an independent credentialed professional (PE, RA, CEM, BEAP, or EMP, never an employee) reviewing your ENERGY STAR Portfolio Manager data, completing and signing the official Data Verification Checklist, and submitting it to the City’s Office of Climate Action, Sustainability and Resiliency (CASR). You can verify either your 2024 or 2025 calendar-year data, and if you have already completed a target adjustment you are already covered. Skip both with no extension on file and you are non-compliant on benchmarking — a $2,000-per-year fine, rising to as much as $10 per square foot for buildings that never benchmarked.

What Energize Denver is — and what it is not

Energize Denver is an energy-efficiency performance policy. It is worth killing three myths before the deadline panic sets in, because they drive owners toward the wrong (and more expensive) decisions:

• It is not an electrification mandate. Buildings are not required to electrify to comply.
• It is not a mandate to rip out working HVAC or water heating before end of life.
• It is not a flat “cut energy 30%” rule. The citywide goal is a 30% reduction, but every building gets its own unique target.

The policy splits covered buildings into two groups. Buildings 5,000–24,999 sq ft (roughly 8,000 of them) upgrade lighting to LED or install solar to cover 20% of usage. Buildings 25,000 sq ft and larger (roughly 3,000) meet building-specific efficiency targets, with the final target due in 2032 for most properties. This post is about the larger group, because that is who carries the June 1 data verification requirement.

One encouraging data point from the City: 36% of large buildings already meet the policy’s requirements, up from 15% two years ago. The deadline is real, but the trend is in owners’ favor.

Obligation 1: Benchmarking (due June 1)

Benchmarking is how you tell the City the story of your building. CASR only sees what you submit in ENERGY STAR Portfolio Manager (ESPM), and they compare it against last year’s submission. Here is the trap: you can technically comply with the bare minimum, but thin or wrong data produces an efficiency target that does not reflect how your building actually runs — and a wrong target is harder and more expensive to hit.

Before you submit, run the City’s benchmarking checklist:

1. How big is the building? Verify Gross Floor Area — exterior wall to exterior wall, not just rentable space.
2. How is it used? Confirm property-use types are accurate.
3. What parking do you offer? Parking energy can often be excluded.
4. How many weekly operating hours?
5. Any special features or facilities?
6. Is your energy data correct?

Submit the benchmarking report on time even if your data verification is still in flight. They are separate obligations.

Obligation 2: Data verification (also due June 1)

Data verification is the City’s mechanism for confirming the data in your benchmarking report is accurate and detailed. A credentialed, independent third party reviews your ESPM data, generates and completes the ENERGY STAR Data Verification Checklist, signs it, and submits it to CASR.

It is required twice over the life of the policy:

1. Once by the end of the 2026 benchmarking season (this June 1). Verify either 2024 or 2025 calendar-year data. If you have already completed a target adjustment, you are done — verification is built into that process.
2. Again in your final performance evaluation year — 2032 for most buildings.

Who can sign it. The verifier must hold one of these credentials, in good standing, and must not be an employee of the building or owner: Professional Engineer (PE), Licensed Architect (RA), Certified Energy Manager (CEM), Building Energy Assessment Professional (BEAP), or Energy Management Professional (EMP). Data verification, along with energy audits for timeline extensions and custom targets, is one of the only items in the entire policy that legally requires a third party.

Why do it now, not later. Getting verified in 2026 is not just box-checking:

• You will know exactly where your building sits against its 2028 interim target.
• You will not have to verify again until your final target year (most likely 2032).
• Your building receives any Standard Target Adjustment it qualifies for, which can make your final target more realistic.

A few practical notes CASR gives verifiers: no on-site visit is required (verifier’s judgment), the Indoor Environmental Quality section can be marked N/A, no stamp is needed, and if your building is already ENERGY STAR Certified for the relevant year with at least a six-month overlap, that checklist can be reused.

The seven-step data verification process

This is the whole workflow, in plain English:

1. The building owner connects with the data verifier in ESPM.
2. The owner shares the property with the verifier in ESPM (Full Access).
3. The owner gathers supporting information.
4. The verifier confirms the benchmarking data and may help correct it.
5. The verifier generates the Data Verification Checklist in ESPM (Reporting → ENERGY STAR Performance Documents).
6. The verifier completes and signs the checklist — four sections: whole-property characteristics, property-use details, energy consumption, and the verifying professional’s signature.
7. The signed PDF is submitted to CASR via the Data Verification Submission Form (in the portal under Forms & Applications).

The benchmarking report for the verified year must match the checklist. Keep the signed checklist on file.

What it actually costs to do nothing

Here is the exposure, with sources, so you can size the risk honestly:

Two things matter here. First, the City does not publish a separate fine for failing to data verify — it rolls into benchmarking non-compliance, so the operative baseline number is $2,000 per year. Second, the $10 per square foot penalty is the genuinely frightening one, but it applies specifically to buildings that have never benchmarked or whose data predates 2019 — on a 50,000 sq ft building that is up to $500,000. Either way, you get flagged “Out of Compliance” in the City portal. (You may have seen a $4,000 figure circulating; it is not documented in the ordinance — the defensible number is $2,000 per year.)

If you are out of runway: the extension

If you cannot complete verification before June 1, the City lets you file a Data Verification Extension Request — one per building. You have to actually file it, correctly, before the deadline. Filing the extension protects you from the non-compliance fine while the verification work is finished.

This is the path I use for owners who come to me late. As a Certified Energy Manager (CEM) licensed by Energize Denver, I can file your extension request to protect you from the fine, complete the third-party data verification, and make sure your building captures any Standard Target Adjustment it qualifies for — typically inside two weeks. If you have not benchmarked or verified yet, the worst move is to let June 1 pass in silence. File something.

Field note

The buildings that get burned by this deadline are rarely the ones that ignored the policy — they are the ones who assumed benchmarking and data verification were the same task, filed the benchmarking report, and never realized verification was a second, separate obligation due the same day. If your portal shows “Not Submitted” or your Data Verification Requirement Satisfied box is unchecked, you are exposed, regardless of how clean your Portfolio Manager data looks. As a CEM licensed by Energize Denver, the play I run for owners who come to me close to the deadline is simple: file the Data Verification Extension Request first to stop the clock, then complete the verification and lock in any Standard Target Adjustment the building qualifies for. The extension is the cheap insurance most owners don’t know exists — file something before June 1 rather than nothing.

Sources

• City and County of Denver, Energize Denver — Buildings 25,000 sq ft or Larger: Performance Requirements
• Energize Denver, Right on Target — Data Verification (Spring 2026 owner briefing), CASR
• Energize Denver Technical Guidance, Sec. 4.5 (Data Verification) and Ch. 4 (Annual Benchmarking Requirements)
• EPA, ENERGY STAR Portfolio Manager — Data Verification Checklist and Licensed Professional Guide
• Energize Denver Help Desk: (844) 536-4528 · [email protected]

About the author

Chris Mbori

Founder of Eenovators Limited (East African ESCO), partnering with AIM Dynamics. Built Eagles and the ADM portal. AEE Energy Manager of the Year (Sub-Saharan Africa). 10 AEE certifications. Licensed Engineer. Field journal — hype-skeptical, field-tested.

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