The SEC comment window on killing the 2024 climate disclosure rule closed. That is a federal filing story. It is not a hall pass for a New York building.
If you manage square footage over 25,000 in this city, Local Law 97 did not notice Chairman Atkins. The cap, the $268-per-ton penalty, and the DOB calendar are still the job.
What actually ended
On May 29, 2026 the Commission proposed to rescind the March 2024 climate disclosure rules in full (Release 2026-49). The rules have been stayed since April 2024. In March 2025 the Commission stopped defending them. Comments ran 60 days after the June 3 Federal Register notice — through early August. The proposal is not a final repeal yet. It is also not a stay of any city or state building law.
We already walked the federal timeline here: SEC climate disclosure rule — requirements, timeline, compliance. Do not reread that as “ESG is over.”
What did not end
NYC Accelerator still has it in one sentence: most buildings over 25,000 gross square feet sit under an annual carbon cap, with a $268 per metric ton CO2e penalty for going over. First compliance period is 2024–2029. Limits tighten in 2030. Reports go to DOB, certified by a PE or RA, through BEAM.
The annual report is due May 1, reflecting last year’s energy. DOB allows a grace period through June 30. For 2026 filings only, owners who applied for the $60 BEAM extension by June 30, 2026 got until August 29, 2026. If you did not apply, that extra month is not sitting there waiting. See the NYC Accelerator LL97 page and DOB’s LL97 site.
The stack (LL84 / LL88 / LL97 / LL33) is still one calendar: NYC building compliance stack.
What to do this month
- If you have the August 29 extension, file. Do not spend the week rewriting a 10-K climate section that the SEC is trying to delete.
- If you missed June 30, treat it as late and call the RDP. Late filing and over-cap are different penalties. Mixing them up is how boards get surprised.
- Keep the 2030 model. Accelerator’s public estimate: most buildings clear the first period; more than half are on track to miss 2030–2034. That is the real money.
- Article 321 buildings (certain affordable and houses of worship) are a different path. Do not copy a market-rate 320 playbook onto them.
Federal disclosure is a form. LL97 is a boiler and a bill. Run the one that fines the BIN.
Sources: SEC Release 2026-49 (May 29, 2026); Federal Register June 3, 2026; NYC Accelerator — Local Law 97; NYC DOB LL97.