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Maryland BEPS Compliance:
What Building Owners Need to Know Now

Maryland Department of the Environment Notice of Required Action letter for BEPS compliance with modern commercial building

If you recently received a “Notice of Required Action” from the Maryland Department of the Environment (MDE), it means your property appears on the state’s list of covered buildings under the Building Energy Performance Standards (BEPS). 

These letters can feel abrupt, but they are simply notifications. Understanding what the notice means and what steps are required will help you move forward confidently. 

What the MDE Notice Means 

Maryland BEPS applies to many commercial and multifamily buildings, generally those 25,000 to 35,000 square feet and larger. 

If you received a notice, it typically indicates one of two things: 

  • MDE has not yet received your building’s 2024 benchmarking data, or 
  • Your building information in ENERGY STAR® Portfolio Manager may be incomplete or incorrect. 

The submission deadline for the 2024 reporting year was September 30, 2025. 

If benchmarking has not been submitted, owners have 35 days from the date of the letter to file the report or to request an exemption if the property qualifies. 

This early step is simply about establishing an accurate baseline. More detailed performance requirements begin later. 

What Owners Need to Do Now 

Most buildings will need to complete four basic actions: 

  • Confirm the building’s coverage

    Review the letter’s UBID, square footage, and building classification to ensure the property is correctly listed.

  • Verify your Portfolio Manager account

    Make sure the building profile exists, is up to date, and reflects whole-building energy usage.

  • Gather complete utility data

    This may include electric, natural gas, district energy, or tenant-metered usage.

  • Submit the 2024 benchmarking report

    Once the data is validated, upload the report to MDE. 

These tasks establish your baseline, something every building will need as BEPS phases in over the next several years. 

Circular diagram showing the BEPS Reporting cycle with four stages connected by arrows: Gather Data (top, green circle with database icon), Submit to MDE (right, blue circle with document icon), Improve Guidance (bottom, green circle with plant/growth icon), and Benchmark (left, blue circle with people comparison icon). Arrows flow clockwise in alternating blue and green colors. BEPS REPORTING text appears in the center.

Why Acting Now Matters 

Benchmarking is the first requirement under BEPS. Starting early provides important advantages: 

  • Establishes an accurate and defensible baseline 
  • Reduces the risk of penalties or repeated notices 
  • Identifies data issues before performance standards set in 
  • Helps owners plan capital upgrades with better cost visibility 

Maryland will begin phasing in performance requirements in 2030, and buildings with solid baselines today will have more flexibility and lower risk in the years ahead.

Download this quick MD BEPS guide. 

BEPS Compliance 15-Year Timeline

June 1, 2025

Annual benchmarking reporting begins for covered buildings.

June 1, 2026

Benchmarking data for calendar year 2025 due; first year of required third-party verification.

2030-2034

First interim period of performance standards begins (net direct GHG emissions reductions).

2035-2039

Second interim period of performance standards.

2040 and beyond

Final standard: net-zero direct GHG emissions required for covered buildings.

June 1st Benchmarking Report Due Each Year

How an Energy Consultant can Help 

Many owners and operators prefer support during this process, especially when managing multiple properties, tenant-meters, mixed-use buildings, or data gaps. 

A qualified energy consultant provides: 

  • Coverage and UBID review

    Confirming that your building is correctly listed and categorized. 

  • Portfolio Manager setup or correction

    Ensuring the building profile is complete, accurate, and ready for ongoing reporting. 

  • Utility data coordination

    Collecting and validating usage from utilities or tenants. 

  • Benchmarking and MDE submission

    Preparing and submitting the 2024 report within the required timeframe. 

  • A forward-looking performance roadmap

    Outlining efficiency strategies, funding opportunities, and areas to improve before BEPS performance standards begin. 

They guide owners through the process with clarity while protecting long-term building performance and operating budgets. 

Four-step BEPS reporting process shown as circular icons in a row. Step 1 - Gather Data (green circle with database icon): 12 months of utility data plus building details, confirmed covered building status. Step 2 - Benchmark (blue circle with people comparison icon): Enter QA data in Energy Star Portfolio Manager, generate results. Step 3 - Submit to MDE (green circle with document icon): Submit BEPS report, resolve data flags and delinquency notices. Step 4 - Improve Guidance (blue circle with hand holding plant icon): Controls, upgrades, electrification, incentives, and capital priorities.

Next Step for Building Owners 

The simplest way to move forward is to review your letter and confirm where your building stands in the benchmarking process. 

If you would like support, Spectrum Energy can help verify coverage, gather data, complete benchmarking, and submit the report on your behalf. 

Schedule My BEPS Review

About the Author

Chet Knaup

Chet Knaup

PRESIDENT, SPECTRUM ENERGY

Chet’s interest in energy efficiency began in 2000 while working for an HVAC manufacturer. His passion grew during his consulting engineering career in Portland, OR, one of the greenest cities in the US. Over the past 20 years, Chet has worked on energy efficient projects across multiple countries and five continents. For the past 14 years, he has worked with green building certification programs including LEED and Passive House (PHIUS) projects, serving as Mechanical Engineer, Energy Engineer, Sustainability Consultant, and Project Manager.