What Is Oregon's Building Performance Standard? A Complete Guide for Building Owners

Oregon’s Building Performance Standard (BPS) represents one of the most significant policy changes affecting commercial buildings in the state since energy codes were first established. Under Oregon Revised Statute 330-300, building owners face a compliance mandate that will reshape how properties are managed, monitored, and improved over the coming years. Understanding what the BPS is and how it affects your building is the critical first step in meeting these requirements.

What Is the Oregon Building Performance Standard?

The Building Performance Standard is a regulatory framework that requires large commercial and multifamily buildings to meet specific energy performance targets. Rather than dictating how buildings should be constructed or what systems they must install, the BPS sets benchmarks based on each building’s actual energy performance and size. Buildings that exceed these benchmarks face financial penalties; those that comply gain regulatory certainty and may access substantial incentive programs.

The program is overseen by the Oregon Department of Energy (ODOE) and represents Oregon’s commitment to reducing statewide greenhouse gas emissions while maintaining economic competitiveness in commercial real estate. The BPS applies a science-based, data-driven approach rooted in ASHRAE Standard 100, which is the industry’s recognized standard for energy auditing and building performance improvement.

Who Must Comply?

The BPS applies to buildings that meet specific size thresholds. The primary requirement affects buildings of 35,000 square feet or larger. This includes office buildings, retail centers, hotels, apartments, hospitals, schools, and industrial facilities. The program is statewide, so if your property is located anywhere in Oregon and exceeds the size threshold, compliance is mandatory.

The BPS does not distinguish between public and private ownership. Government buildings, nonprofit facilities, and private commercial properties all face identical compliance requirements. Similarly, both newly constructed buildings and older existing structures are subject to the same standards, though buildings constructed after the BPS effective date may have different benchmarks.

Key Requirements: What Does Compliance Involve?

Meeting Oregon BPS compliance involves three fundamental components:

Benchmarking: Building owners must track and report actual energy consumption data. This benchmarking process began in January 2025, creating a baseline of your building’s current performance. Accurate benchmarking data is essential for determining whether your building meets the required energy performance level.

ASHRAE Level 2 Energy Audits: For most buildings, compliance requires a comprehensive energy audit conducted to ASHRAE Standard 100 with Oregon-specific amendments. This Level 2 audit goes far beyond basic energy consumption analysis. Auditors physically inspect major building systems, analyze operational efficiency, and identify cost-effective improvement opportunities. The audit must be performed by a qualified energy auditor (QEA) who meets specific education and certification requirements.

Performance Standards: Your building must achieve energy performance targets based on its building type and size. These targets are expressed in energy use intensity (EUI)—a measurement of energy consumption per square foot. Different building types have different target EUI values, reflecting the varying baseline energy needs of hospitals versus office buildings, for example.

Why Was the BPS Established?

Oregon enacted the BPS as part of a comprehensive strategy to reduce greenhouse gas emissions from the built environment. Buildings account for a substantial portion of Oregon’s energy consumption and carbon footprint. Traditional building codes focus on new construction; the BPS targets the existing building stock, where most emissions actually occur. By setting performance standards and requiring regular benchmarking and auditing, the state aims to drive continuous improvement in building efficiency without prescribing specific solutions.

The BPS also creates market incentives for building improvement. Incentive programs through Energy Trust of Oregon offer substantial financial support for buildings that achieve early compliance, making upgrades more financially attractive. These incentives reward proactive building owners and create a competitive advantage in the real estate market.

Compliance Deadlines: What’s the Timeline?

The BPS operates on a tiered timeline. Tier 1 buildings (typically larger properties or those with higher energy intensity) face a compliance deadline of 2028. Tier 2 buildings have until 2030. Benchmarking data, collected beginning in January 2025, is used to determine which tier each building falls into and whether it can meet the energy performance target.

This timeline may seem distant, but it’s important to understand that compliance activities must occur now. Buildings requiring audits must complete them well before 2028 or 2030. Qualified energy auditors may become increasingly difficult to book as deadlines approach. Early action provides significant advantages in scheduling, incentive availability, and cost control.

Financial Implications and Incentives

Non-compliance carries financial penalties. Buildings that fail to meet their energy performance target by the compliance deadline face fines and ongoing financial consequences. However, buildings that achieve early compliance can access substantial incentive funding through Energy Trust of Oregon, worth up to $0.85 per square foot. For a 50,000-square-foot building, this represents potential incentive funding of $42,500—a meaningful reduction in improvement costs.

Next Steps for Building Owners

If your building is 35,000 square feet or larger, Oregon BPS compliance is mandatory. The most important immediate action is to verify your building’s current benchmarking status and determine your compliance tier and deadline. From there, connecting with a qualified energy auditor is essential. These professionals can explain what an audit will involve, provide cost estimates, and help you develop a roadmap to compliance.

The BPS is not optional and avoiding it is not an alternative strategy. Buildings that fail to comply will face penalties that only increase over time. However, buildings that engage proactively with the process can minimize costs, access incentives, and potentially discover improvement opportunities that enhance property value and operational efficiency.

Get Started on Your Oregon BPS Compliance Journey

Understanding the BPS is just the beginning. Every building’s situation is unique, and the compliance path that works best for yours depends on its specific characteristics, current performance, and financial goals.

Oregon Building Compliance specializes in helping building owners navigate the BPS process, from initial benchmarking verification through audit completion and improvement planning. Our team works with property managers and owners to explain requirements, identify qualified energy auditors, and develop cost-effective compliance strategies.

If you have questions about whether your building must comply or what your next steps should be, we’re here to help. Contact Oregon Building Compliance today to discuss your building’s BPS obligations and begin the path to successful, cost-effective compliance.