Compliance
The Law: CBPS Overview
Written by
SEM Editorial Team
A practical guide to Washington’s Clean Buildings Performance Standard, including who is covered, what each tier requires, and how owners can prepare.
Washington’s Clean Buildings Performance Standard, commonly called CBPS, changes how many existing buildings are expected to manage energy. Instead of treating efficiency as an occasional upgrade, the law makes benchmarking, energy planning, operations, and maintenance part of a recurring management process. The Washington State Department of Commerce administers the program, which combines ASHRAE Standard 100-2018 with state requirements in chapter 194-50 WAC.
The policy began with House Bill 1257 in 2019, after the Legislature identified buildings as the state’s second-largest source of greenhouse gas emissions and found that building-sector emissions had increased 50 percent since 1990. Senate Bill 5722 expanded the program in 2022 by creating Tier 2 requirements. Later legislation added and adjusted compliance options, including House Bill 1390 in 2023 and House Bill 1543 in 2025. Commerce filed final rule amendments tied to the 2025 changes on July 21, 2026, with adoption scheduled 31 days after filing, so owners considering a newly added pathway should confirm the rule’s effective status before relying on it.
Coverage depends on both size and use. Tier 1 generally includes buildings with more than 50,000 gross square feet of combined nonresidential, hotel, motel, and dormitory space, excluding parking. Tier 2 generally includes buildings with more than 20,000 and no more than 50,000 gross square feet of those uses, plus multifamily residential buildings over 20,000 square feet. Federal buildings and buildings owned by federally recognized tribes are not required to comply, and other exemptions have specific legal criteria. Owners should confirm each property’s status rather than rely on square footage alone.
Both tiers require reliable energy information and formal management practices. Owners benchmark through ENERGY STAR Portfolio Manager, develop and implement an energy management plan, and establish an operations and maintenance program. Tier 1 also includes an energy-performance requirement or an approved alternative compliance method. Energy use intensity, or EUI, is one central measure because it compares annual energy use with a building’s floor area. Tier 2 owners calculate and review an EUI target, but they are not currently required to meet that target.
The first Tier 1 deadline, for buildings over 220,000 square feet, was June 1, 2026. Initial reporting is due June 1, 2027 for Tier 1 buildings from 90,001 to 220,000 square feet and June 1, 2028 for Tier 1 buildings from 50,001 to 90,000 square feet. Tier 2 documentation is due July 1, 2027. Reporting generally repeats every five years. Extensions, exemptions, conditional compliance, and penalties all have detailed rules, which makes current Commerce guidance and the Clean Buildings Portal essential sources.
A sensible first step is to verify the building record and ownership information in the portal. From there, owners can gather utility and meter data, confirm gross floor area and property-use details, establish or review the Portfolio Manager account, and identify who will own the work internally. Starting the energy management and operations and maintenance documents early gives facility teams time to correct data problems, document current systems, and connect practical improvements with maintenance and capital plans.
Student Energy Managers helps building owners turn these requirements into an organized work plan. SEM supports benchmarking and energy tracking, energy management planning, operations and maintenance documentation, building review, and coordination with the people responsible for formal compliance decisions. The same process can also reveal avoidable energy waste and give facility teams a clearer picture of how their buildings are performing.