SB 48: California's Upcoming Building Performance Standards

SB 48 (Senate Bill 48) is California legislation that expands and strengthens the state's building energy benchmarking and performance requirements. It is part of California's broader effort to decarbonize the built environment by 2045 and is expected to lower the size threshold for mandatory benchmarking and introduce building performance standards (BPS) that require buildings to reduce energy use over time.

SB 48 implementation is being phased in through the 2025–2026 regulatory cycle. The California Energy Commission is developing the implementing regulations, with initial requirements expected to take effect in 2026. Building owners should monitor CEC rulemaking updates closely.

AB 802 requires annual energy benchmarking and reporting. SB 48 goes further by introducing Building Performance Standards (BPS) — mandatory targets for reducing a building's energy use intensity (EUI) over time. Buildings that fail to meet BPS targets will face compliance obligations beyond just reporting.

SB 48 is expected to expand coverage to smaller buildings than AB 802's current 50,000 sq ft threshold. The exact thresholds are being determined through the CEC rulemaking process. Buildings that are currently exempt from AB 802 may become subject to SB 48 requirements.

Building owners should: (1) begin benchmarking now even if not yet required, to establish a baseline EUI, (2) commission an ASHRAE Level II energy audit to identify upgrade opportunities, (3) prioritize high-ROI upgrades like LED lighting and HVAC optimization that will reduce EUI, and (4) monitor CEC rulemaking for final threshold and timeline announcements.