What are Massachusetts DOER Reporting Requirements for Large Buildings?

Municipalities, building owners and facility managers across Massachusetts need to stay on top of emerging energy reporting requirements to remain compliant and avoid costly penalties. One of the latest regulatory mandates comes from the Massachusetts Department of Energy Resources (DOER), which now requires annual energy usage reporting for certain large buildings under what is known as the Large Building Energy Reporting (LBER) program.

This blog breaks down what the LBER requirement is, who it applies to, how it connects with other programs like BERDO and BUEDO, what the reporting process entails, and how to stay compliant.

What is the LBER Requirement?

The Large Building Energy Reporting (LBER) requirement is a new initiative from the Massachusetts DOER. It applies to any building in the state with a gross floor area of 20,000 square feet or greater, whether commercial, residential, institutional or mixed-use. 

The goal of LBER is to support Massachusetts' broader climate goals by increasing transparency around building energy use, identifying opportunities for efficiency improvements, and guiding future energy policies. Importantly, LBER is distinct from local ordinances like BERDO (Boston) and BUEDO (Cambridge), though there are overlapping themes.

How is LBER Different from BERDO or BUEDO?

While BERDO and BUEDO are city-specific policies targeting energy use in Boston and Cambridge, LBER is a statewide regulation. The DOER has taken care to ensure that LBER does not create conflicting reporting obligations. If you’re already reporting under BERDO or BUEDO, your submission may satisfy LBER requirements, but you must still confirm compliance through the state’s process.

Read this Veolia Blog to learn more about the difference between BERDO and BUEDO.

Who Needs to Report Under LBER?

You must report if you:

• Own or manage a building in Massachusetts that is 20,000 square feet or larger.
• Operate as a municipality with qualifying buildings.
• Manage facilities like hospitals, universities, commercial buildings or residential complexes.

This applies whether your building is publicly or privately owned. If your organization has reputational risks tied to environmental performance or ESG metrics, LBER compliance is especially critical. Noncompliance can lead to financial penalties and damage public perception.

Are There Exceptions to LBER Reporting?

Yes, some buildings may qualify for exemptions, including:

• Vacant buildings or those unoccupied for more than 50% of the year.
• Demolished properties.
• Buildings under construction or major renovation.
• Properties owned by bankrupt entities or under legal receivership.

Exemptions are not automatic—owners must apply and provide documentation.

What Happens if You Don’t Comply?

Failure to comply with LBER can result in fines of up to $150 per day per building until compliance is achieved. The DOER uses tools like:

• Cross-referencing property tax records.
• Reviewing public building databases.
• Analyzing past energy benchmarking records.

In short, they will know if a property isn’t reporting when it should be.

Who Submits the Report: Landlord or Tenant?

In most cases, building owners (including landlords) are responsible for LBER reporting. Tenants aren’t directly responsible unless specified in the lease. However, tenants may need to provide energy data—particularly in triple-net leases—so landlords should start engaging tenants early to collect the necessary utility data.

How Do You Report to DOER?

The reporting process includes:

1. Create a Portfolio Manager account via the U.S. EPA’s ENERGY STAR program.
2. Collect 12 months of energy consumption data (electricity, gas, steam, fuel oil if applicable).
3. Enter building and energy data into Portfolio Manager.
4. Generate and submit the report through the LBER reporting portal.

Is There a Materiality Threshold for Fuel Oil Consumption?

While DOER expects comprehensive data, small amounts of fuel oil (e.g., backup generators or rarely used heating systems) may not significantly affect reporting. However, if fuel oil is a regular energy source, it must be included.

When in doubt, include it—or consult a qualified energy professional.

What Happens if Reporting Platforms Change?

With recent uncertainty around the future of the EPA’s ENERGY STAR Portfolio Manager, it’s critical to ensure your reporting processes and data storage strategies are future-proofed. While Portfolio Manager remains active today, changes could impact how and where you report energy data in the future.

Are your systems and data prepared for this kind of disruption? If not, now is the time to plan.

Key LBER Deadlines:

• Reporting Deadline: May 31 of each year (starting in 2025 for 2024 data).
• Exemption Requests: Typically due 30-60 days before the main reporting deadline (confirm with DOER guidance).

Need Help Future-Proofing Your LBER Compliance Strategy?

There are experts here to help you.

• Secure and consolidate historical data to safeguard against platform changes like a potential Portfolio Manager shutdown.
• Establish backup reporting strategies to stay ahead of regulatory uncertainty.
• Simplify tenant data collection and ensure smooth, accurate reporting.
• Assess compliance risks across your entire building portfolio.