Building Performance Standards (BPS) Compliance Kit

A practical compliance operating system: inventory → applicability → reporting calendar → gap plan (not legal advice)

Decision KitsDecision Kit60 min

Important: This is operational education, not legal advice. BPS rules vary by jurisdiction and change over time. Use qualified counsel and local expertise for final interpretations.

What you'll accomplish

  • Build a BPS regulatory inventory (what rules apply, where, and when)
  • Determine which buildings/assets are covered (and why)
  • Create a compliance calendar and responsibility model
  • Identify gaps (data, performance, documentation)
  • Build a compliance plan aligned with your portfolio roadmap

Who this is for

  • •Sustainability teams responsible for compliance readiness
  • •Asset/portfolio managers responsible for building obligations
  • •Facilities teams supporting building performance improvements
  • •Finance teams responsible for penalties, budgets, and planning

When to use this

Use this when:

  • •You operate in jurisdictions with performance/benchmarking requirements
  • •You need a defensible process to avoid surprise deadlines and penalties
  • •Leadership wants a single view: "Are we compliant? Where are the risks?"

Prerequisites (minimum viable)

  • •Portfolio roster with addresses and basic size attributes (or similar)
  • •Utility data pipeline (even partial) for benchmarking and reporting
  • •A data governance approach for evidence and QA

Related resources:

Quick start (60 minutes)

  • Create Regulatory Inventory (Template 1) for your top jurisdictions
  • Build Building Applicability Table (Template 2)
  • Build a compliance calendar for the next 12 months (Template 3)
  • Identify top 5 "high risk" buildings (Template 4)

BPS in plain English

BPS programs typically require some combination of:

  • •Benchmarking / reporting (submit energy data periodically)
  • •Performance targets (meet a threshold or improve by a deadline)
  • •Documentation (proof of data sources, audits, improvement plans)
  • •Penalties (fees or fines if not compliant)

Beginner rule: Compliance is mostly a process problem until proven otherwise. If you can't meet deadlines and prove your data, you'll lose even if buildings are improving.

Step-by-step

Step 1 — Build a regulatory inventory (don't rely on memory)

Create a table that tracks:

  • •jurisdiction
  • •what is required
  • •who is covered
  • •reporting deadlines
  • •penalty concepts
  • •responsible owner internally
  • •links to official references (store internally)

Step 2 — Determine applicability building-by-building

For each building:

  • •address/jurisdiction
  • •size/threshold indicator (if applicable)
  • •covered/not covered/unknown
  • •what the next deadline is

Step 3 — Build a compliance calendar (treat it like renewals)

Set alerts:

  • •T-120, T-90, T-60, T-30 for each deadline
  • •Assign owners

Beginner rule: Deadlines are your control plane. Don't wait for "reporting season."

Step 4 — Data readiness check

For covered buildings, confirm:

  • •utility accounts identified
  • •kWh and billing periods available
  • •evidence links stored
  • •QA checks in place
  • •exceptions log running

Step 5 — Performance gap analysis (directional is okay at first)

For each covered building:

  • •performance trend (improving vs not)
  • •biggest constraints (tenant utilities, metering, old systems)
  • •what interventions are feasible in the next cycle

Step 6 — Compliance action plan

Build a plan with:

  • •reporting tasks
  • •data gap closures (metering, tenant data)
  • •operational improvements (controls/RCx)
  • •capex improvements (bundled in capital plan)
  • •documentation and sign-off

Templates

Template 1 — Regulatory Inventory

Regulatory Inventory

| Jurisdiction | Requirement type (benchmarking/target/other) | Covered threshold concept | Reporting deadline(s) | Penalty concept | Internal owner | Evidence link (official source stored internally) | Notes |
|---|---|---|---|---|---|---|---|

Template 2 — Building Applicability Table

Building Applicability Table

| Building | Address | Jurisdiction | Size/threshold indicator | Covered? (Y/N/Unknown) | Next deadline | Data readiness (H/M/L) | Performance risk (H/M/L) | Notes |
|---|---|---|---|---|---|---|---|---|

Template 3 — Compliance Calendar

Compliance Calendar

| Date | Building/Jurisdiction | Requirement | Owner | Prep start date | Status | Notes |
|---|---|---|---|---|---|---|

Template 4 — Risk Register

Risk Register

| Building | Risk | Likelihood (L/M/H) | Impact (L/M/H) | Mitigation | Owner | Due date |
|---|---|---|---|---|---|---|

Template 5 — Compliance Action Plan

BPS Compliance Action Plan

BPS Compliance Action Plan

Scope:
Reporting deadlines:
Key data gaps:
Performance risks:
Plan (next 90 days):
- data pipeline improvements
- tenant data collection
- controls/RCx actions
Plan (next 12–36 months):
- capex bundles
- electrification feasibility (where applicable)
Governance:
- monthly compliance check-in
- quarterly steering

Common pitfalls

  • No inventory → surprise deadlines
  • Treating compliance as "Sustainability's problem" without ops and finance ownership
  • Incomplete evidence and QA → reporting becomes fragile
  • Ignoring tenant data realities (multi-tenant complexity)
  • No sign-off process → nobody is accountable

Change log

v1.0 (2026-01): Latest release