Indianapolis struggles to enforce building energy benchmarking rules as compliance lags ahead of 2026 disclosures

A city policy built around measuring energy use

Indianapolis’ energy-use benchmarking requirement for large buildings is entering a consequential phase as the city prepares to publish building performance data in 2026. The local Benchmarking and Transparency Ordinance, passed in July 2021, requires covered properties to track and report annual energy and water use using the U.S. Environmental Protection Agency’s ENERGY STAR Portfolio Manager platform.

The policy applies to city-owned buildings at least 25,000 square feet and to non-city buildings in commercial, multifamily and industrial categories beginning at 50,000 square feet, with requirements phased in over multiple years. Annual reporting is tied to a June 1 deadline, and submissions are structured through a data-sharing process inside Portfolio Manager.

Phased rollout and the 2026 transparency milestone

The ordinance was designed to start with municipal buildings and expand to larger private properties. The implementation schedule includes initial voluntary participation for many building types before later phases make compliance mandatory. The public-facing element—posting benchmarking results—was built in as a later step, with city buildings’ information shared first and broader covered-building information expected to be published in 2026.

In practical terms, the 2026 disclosure timeline raises the stakes for building owners who have not yet established consistent processes for gathering whole-building utility data—especially in properties with multiple tenants where usage information may be distributed across separate meters and accounts.

Why compliance has proven difficult

Benchmarking typically requires assembling complete annual electricity, natural gas and water consumption data, then entering or uploading it into Portfolio Manager. For some owners, the task can be straightforward if the property is served by a single “master” meter. For others, particularly multi-tenant buildings, reporting can require requests for aggregated whole-building figures from utility providers or coordination with tenants.

The city has attempted to lower barriers through training and technical assistance, including guided workshops that walk building representatives through Portfolio Manager setup and reporting steps. Even with support options available, the administrative lift and the learning curve of compliance tools can slow participation—particularly among owners without dedicated energy management staff.

Enforcement structure and what comes next

Indianapolis’ ordinance includes financial penalties for noncompliance that begin at $100 and rise to $250 in subsequent years. The city has emphasized outreach to building owners and managers as it seeks to increase reporting rates before the public disclosure phase begins.

Benchmarking programs in other U.S. cities have been used to identify inefficient buildings, target retrofits, and track progress over time. In Indianapolis, city officials have framed the policy as a data-first approach—intended to create a baseline, improve accuracy year over year, and ultimately provide transparency to tenants, owners and the broader community.

• What is required: annual reporting of energy and water use for covered buildings through Portfolio Manager.
• Key deadline: June 1 reporting cycle.
• Major next step: public release of covered-building benchmarking data starting in 2026.

Benchmarking is designed to measure how buildings perform relative to peers and to create consistent records that can inform operational and capital improvement decisions.

As the 2026 transparency date approaches, the city’s near-term challenge is operational: moving more covered properties from awareness to routine, on-time reporting, while improving data completeness and consistency across a diverse building stock.