Tier 1
Nonresidential/hotel/motel/dormitory floor area over 50,000 gross SF.Tier 1 reporting phases start June 1, 2026 for buildings over 220,000 SF, then June 1, 2027 and June 1, 2028 for smaller Tier 1 cohorts.
National expansion brief
Washington CBPS is a clean example of deadline-driven portfolio risk.
Washington's Clean Buildings Performance Standard uses phased Tier 1 and Tier 2 workflows through Commerce's portal. Owners need to identify covered buildings, confirm portal access, benchmark, prepare documentation, and file on the right schedule.
Why this belongs in Deadline Watch
Large national market, clear deadlines, high document load.
Washington is a strong non-Colorado proof page because the program is structured, phased, and portfolio teams need early planning rather than last-minute filing help.
Tier 2
20,000+ to 50,000 SF buildings plus multifamily over 20,000 SF.Tier 2 reporting starts July 1, 2027 and uses portal-based ownership confirmation and building-record workflows.
Owner workflow
Portal access, benchmarking, EMP/O&M documentation, and reporting records.CBPS is document-heavy. The work is not just finding a target; it is organizing the evidence trail.
Phased deadline watch
Key Washington CBPS dates
Dates below come from the structured Washington CBPS program profile. Re-check Commerce guidance before owner-specific filing advice or penalty language.
Tier 1
Buildings over 220,000 SF
First Tier 1 reporting cohort: June 1, 2026.
Near-termJune 1, 2026
Tier 1
90,000 to 220,000 SF
Second Tier 1 cohort: June 1, 2027.
June 1, 2027
Tier 1
50,000 to 90,000 SF
Third Tier 1 cohort: June 1, 2028.
June 1, 2028
Tier 2
20,000+ SF and multifamily cohort
Tier 2 reporting starts July 1, 2027. Owners can confirm portal access and ownership records before the deadline year.
Tier 2July 1, 2027
Have Washington assets in the portfolio?
Start with a risk review that separates Tier 1, Tier 2, likely exempt, and unknown records before compliance documentation gets urgent.