Compliance Holds and Timeline Extensions
Energize Denver is designed to be flexible because every building is different.
What Options are Available?
If your building is facing circumstances that make it hard to meet your energy efficiency target on time, there are two options that can adjust when you need to comply:
-
An Interim Compliance Hold is a short-term pause for a temporary situation.
-
A Timeline Extension gives buildings more time to carry out a longer-term compliance plan.
Both options change your building's timeline, not its target. If you believe your target itself doesn't reflect your building's real conditions, that's a different process — visit Get the Details Right for information about Target Adjustments.
Understanding Your Current Timeline
You can find your building’s target years using the Performance Requirements Look Up Tool.
Most large buildings have an interim target year in 2028 and a final target year in 2032. That timeline is itself the result of a timeline extension offered to all buildings during the 2025 benchmarking submission process. If you did not submit your 2025 benchmarking (covering 2024 energy data), you can submit that now and still opt into the 2028/2032 timeline extension.
Start With the Help Desk
Both Interim Compliance Holds and Timeline Extensions have different eligibility criteria and documentation requirements, and the right choice depends on your building's specific situation. Before you apply, schedule a call with the Help Desk. Our team will help you understand which option fits, what you'll need to submit, and how it affects your deadlines.
Short-Term · 24 months
Interim Compliance Hold
An Interim Compliance Hold is a temporary, two-year (24-month) pause on the evaluation of your performance requirements, intended for buildings working through a short-term situation. You'll still submit your annual benchmarking report during the hold, and you'll check in with the city at the 12-month mark to share your progress.
At the end of the two years, you have options depending on where things stand:
-
If your situation has resolved and you can meet your target on time, the hold simply ends and no further paperwork is needed.
-
If the situation still exists, you can extend the hold 12 months at a time by submitting updated documentation.
-
If you've recovered but need long-term planning time, you can shift into a Timeline Extension, with up to a year to complete that application.
Common reasons for a hold include financial distress or solvency concerns, high vacancy or a major lease termination, redevelopment or demolition, adaptive reuse project timing, a change of ownership, natural or man-made disasters, a Landmark Preservation Commission review, or an approved benchmarking exemption. See Section 7.1.1 of the Technical Guidance for more details.
What You'll Submit:
Online application form
Narrative letter requesting and explaining the hold, signed by executive leadership
Documentation supporting the reason
Contact information for who will provide annual updates
For full eligibility details and documentation suggestions, see Section 7.1 of the Technical Guidance.
Long-Term · Through 2040
Timeline Extension
A Timeline Extension gives your building more time to carry out a long-term compliance plan. You can request an extension for a single target year (for example, just the 2028 interim target year) or for multiple target years in one application. Extensions are considered as far out as 2039, with a final performance period in 2040.
Common reasons for an extension include planning for the end of a system's service life or electrification, energy service capacity constraints, the downtown district steam loop, a planned major renovation, aligning with your capital planning cycle, and innovative energy efficiency approaches. Equity Priority Buildings may qualify for additional reasons. See Section 7.2.1 of the Technical Guidance for more details.
Near-term action required: Every Timeline Extension includes a near-term requirement to complete a minimum amount of energy efficiency work within 36 months of your extension notice. The Help Desk and Section 7.2 of the Technical Guidance has information on how to achieve that.
What You'll Submit:
Online application form
Documentation supporting your reason(s)
A note on timing and penalties: Applications are accepted at any time. However, Applying by December 31 of the target year keeps your penalty rate the same. Applying later increases that rate. See Section 7.2.3.1 of the Technical Guidance for more information.
What Happens After Approval
Once CASR reviews and approves your application, you'll receive an official notice that lays out your adjusted timeline, any interim projects you've agreed to complete, your interim and final target years, your reporting requirements, and the penalties that would apply if the plan isn't completed as agreed.
Stay on top of the dates outlined in the notice. If deadlines are missed, the extension can be voided and your building will revert to its original target year timeline. And if circumstances change along the way due to supply chain delays, project setbacks, or other reasons, you can request an amendment. Just call the Help Desk as soon as possible so your building isn't penalized for a plan it can no longer meet as written.