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Tier 2 compliance checklist: every step from letter to incentive

Based on WAC 194-50-160 (Annex Y), Commerce's Tier 2 compliance and portal pages, and CBPS 043. Checked 30 Oct 2026.

Washington's Clean Buildings Tier 2 filing has seven items in the portal and a handful of steps that must happen in the right order. This checklist puts them in sequence so nothing holds you up near the 1 July 2027 deadline.

Before you start

  1. Confirm the building is Tier 2. Commercial buildings of 20,001 to 50,000 sq ft and multifamily buildings over 20,000 sq ft, excluding parking garages. Use the free checker.
  2. Find your Commerce letter. Letters went out from 1 July 2025 with a one-time code for claiming the building. No letter? Commerce has a form to request one or shared access.
  3. Set up Secure Access Washington (SAW). The owner, energy manager and QEM each need their own login because each signs from their own account. Never give anyone your password; use Commerce's shared-access process instead.

Benchmarking

  1. Collect twelve consecutive months of energy data for every fuel, measured within the two years before your filing. Ask each utility for a whole-building usage download.
  2. Enter it in ENERGY STAR Portfolio Manager, run the Data Quality Checker, and share the property read-only with Commerce. This produces Form C.

People

  1. Designate a Qualified Energy Manager. Since 21 August 2026 a QEM must complete Commerce's free Tier 2 training and have two years' relevant experience, a supervised fellowship or BOC Level I, or be a Qualified Person. It can be your own staff. Full QEM rules.

Documents

  1. Write the Energy Management Plan to Section 5 (WAC 194-50-050). Commerce's CBPS 039 template is optional. What the plan must contain.
  2. Write the O&M Program to Section 6 and Annex L: inventory, tasks, frequencies, records. O&M Program guide.
  3. Implement it and keep records. Start inspections and the log straight away; your QEM is confirming the program is implemented.
  4. Complete both mandatory Reporting Tools: the EMP Reporting Tool (CBPS 022) and the O&M Reporting Tool (CBPS 023), downloaded from Commerce's document library. Answers must match your documents.

Filing

  1. Complete the portal forms and upload. The QEM sets the energy-use target on Form B; Form C comes from Portfolio Manager; upload the EMP, O&M Program and both Reporting Tools; the owner, energy manager and QEM sign Form A.
  2. Apply for the incentive straight after: flag multifamily if applicable, enter excluded floor area, list each utility account and fuel, give an estimated compliance cost, and have every owner sign.

After you submit

Commerce reviews compliance applications in up to 30 business days and the incentive in up to 14 more. If something needs fixing you get a "corrections needed" email with instructions to resubmit. Once approved, your utility asks for a W-9 and pays the incentive.

The seven portal items at a glance

ItemFormatWho prepares it
Energy Management PlanUpload (any format meeting Section 5)Owner or preparer
EMP Reporting Tool (CBPS 022)Commerce PDF, uploadOwner or preparer
O&M ProgramUpload (any format meeting Annex L)Owner or preparer
O&M Reporting Tool (CBPS 023)Commerce PDF, uploadOwner or preparer
Form A, summary and attestationPortal pageSigned by owner, energy manager and QEM
Form B, building activity and EUI targetPortal pageQEM sets the target
Form C, Portfolio Manager EUIFrom Portfolio ManagerOwner or preparer

Steps 7 to 10 are where most of the time goes. The Tier 2 Filing Kit drafts the EMP, O&M Program, workbook and Reporting Tool answers for your building in five business days, with a portal walk-through for steps 11 and 12. See also deadlines, penalties and cost.

More Tier 2 guides