Compliance for Churches.
There is no religious or nonprofit exemption — coverage runs on square footage. Here’s what congregations need to know, including the exemptions that do exist and when to apply for them.
July 1, 2027
Your compliance deadline, then re-reporting every five years.
Coverage
Is Your Building Covered?
You’re covered if the building is more than 20,000 gross square feet. Worship, fellowship, office and classroom space all count toward that figure, and neither religious use nor nonprofit status changes it. Gross floor area is measured between the exterior surfaces of the enclosing walls and includes corridors, storage, mechanical rooms and elevator shafts; parking garage area is excluded. Above 50,000 square feet of worship, office and other nonresidential floor area the building moves into a larger-buildings program that adds an energy performance target you have to meet — a different pathway from the one this page describes — so the threshold is worth measuring rather than estimating.
If your campus has several structures, whether they’re assessed together depends on metering and ownership. Buildings sharing energy meters on adjoining property under single ownership can comply as a group, filing one plan and one maintenance program between them — but exemptions are still judged building by building.
This Applies To
Congregations, Parishes and Their Facilities Teams.
Churches, temples, mosques, synagogues and other houses of worship in Washington, along with the fellowship halls, offices, classrooms and school wings that sit alongside them.
Requirements
Three Things to Compliance.
There is no performance target to hit. You calculate an energy use intensity target, report your actual performance against it, and that’s the whole obligation — no performance standard for these buildings takes effect before the end of the 2031 legislative session. Nothing here requires you to alter the building.
Benchmark
Twelve consecutive months of whole-building energy use in ENERGY STAR Portfolio Manager, producing your weather-normalized energy use intensity.
Energy Management Plan
Energy performance goals, your EUI target, annual comparison against it, and how you inform residents about efficient energy use.
O&M Program
An inventory of major systems, maintenance tasks, frequencies and who is responsible for them, per ASHRAE Standard 100-2018.
The binding constraint is twelve consecutive months of whole-building energy data, measured within two years of submission — there is no way to manufacture that history retroactively. Your O&M program, by contrast, only has to be implemented by your compliance date; you do not need to run it for a year first. For a congregation that budgets a year ahead through committees, the practical deadline is the budget cycle before the data collection, not 2027.
The Stakes
What Non-compliance Costs.
The maximum administrative penalty is $0.30 per square foot of gross floor area, assessed every compliance period — every five years. Paying it doesn’t discharge the obligation; it buys five years and the same bill again.
Miss the deadline and you’ll receive a notice with at least 30 days to cure. Respond within that window with documentation demonstrating compliance and fines are waived — and you may remain eligible to apply for the early adopter incentive, which pays $0.30 per square foot for doing the same work ahead of time. Respond without it, or elect to pay rather than comply, and you’re assessed the maximum and may lose that eligibility entirely.
Relief
When You Might Not Have to Comply.
There is no exemption for being a church, but there are exemptions for particular situations. Only the first four below carry a size threshold — unconditioned space, low occupancy, no certificate of occupancy and majority industrial use — and singly or combined they have to affect more than half the building. The rest stand on their own. Either way, an exemption is approved in advance rather than claimed after the deadline.
Unconditioned and semi-heated space
If gross floor area minus unconditioned and semi-heated space comes to less than 20,000 sq ft, the building may be exempt — a sanctuary with large unheated volumes is worth measuring carefully before assuming coverage.
Largely unoccupied
If less than half the conditioned floor area was physically occupied across the twelve months before your compliance date. Occasional use still counts as occupancy, so this covers a genuinely shuttered building, not a quiet one.
No certificate of occupancy
If the building held no certificate of occupancy for a consecutive twelve months within the two years before your compliance date.
Majority industrial use
If the building is used primarily for manufacturing or industrial purposes — rare for a congregation, though it can reach a workshop or plant building held alongside the sanctuary.
Financial hardship
Tax arrears, receivership, foreclosure, a mortgage in default — or heavy and immediate financial need caused by events beyond your control, where you lack the debt capacity to cover compliance and have exhausted other reasonable resources.
Pending demolition
The building is scheduled to come down.
An agricultural structure
Agricultural buildings are exempt outright — relevant to a rural parish with barns or storage structures on the property, and assessed per building like every other category.
National security
Added in 2026 for buildings occupied or used for national security purposes. It will not apply to a congregation, but it completes the list Commerce works from.
Granted building by building
Exemptions apply at the building level and never across a campus as a group, so a multi-building site is assessed structure by structure.
The filing window
Applications open two years before your compliance date and close 180 days before it — early January 2027 for a July 2027 deadline. You file Form H with at least two supporting documents, and a certificate covers only the current cycle.
Or ask for more time
A separate two-year extension exists for natural disasters, supply shortages, a recent arm’s-length purchase, active construction, or financial hardship affecting cash flow. You can apply from six months before your compliance date to six months after it.
If an exemption is denied, you go back to demonstrating compliance on the original schedule — which is why the 180-day cut-off matters more than it looks.
Common Questions
Frequently Asked Questions.
No. Coverage depends on floor area and use, not on tax status or who owns the building. Worship, fellowship, office and classroom space all count toward the threshold. The exemptions that do exist are situational — vacancy, unconditioned space, financial hardship and pending demolition among them — and each requires an approved application to Commerce. The full set, and the tests each one has to clear, is set out below.
It depends on metering and ownership. Buildings that share energy meters on contiguous property under single ownership are “connected buildings,” and buildings interconnected by conditioned space are a “complex” — either can comply as a group, filing one Energy Management Plan and one O&M program on Form J instead of Form A. A group works to the earliest compliance date among its buildings, and you must notify Commerce at least 180 days beforehand. Exemptions, though, are always assessed per building.
Not for coverage — physical occupancy means space used by an owner or tenant regardless of how often, so a sanctuary used weekly is occupied. It does change your target, though, and by more than most congregations expect. Targets are scaled by weekly operating hours in bands of 50 or fewer, 51 to 167, and more than 167 — and for worship facilities the hours that count are every hour the building is open for operation, including choir practice, administrative use, committee meetings and classes, not just services. Cross 50 hours a week and the multiplier jumps from 0.9 to 1.7. Hours when only maintenance, security or cleaning staff are present don’t count, and the figure is the average across your twelve months of data.
No — historic buildings are not exempt from the standard. The protection that does exist lets owners omit an individual energy efficiency measure that would compromise historic integrity, and there is a performance-target exemption for historic buildings in the larger-buildings program. Neither changes anything here, because your obligations are benchmarking, a plan and a maintenance program — none of which require you to alter the building.
Yes. A building owner can fill any role the standard defines, and the energy manager may be the owner, an employee, or a contractor. What the program needs is documentation — an inventory of systems, maintenance tasks, frequencies, and who is responsible — not a particular job title. Submission is the one exception: that goes through a Qualified Energy Manager.
Worship facilities carry a site energy target of 39 kBtu/ft²/yr in western Washington and 42 in the east, before adjustment for operating hours. If your building or an addition was permitted on or after July 1, 2016, the target drops by 15 percent for the qualifying floor area. You report against the number — you are not required to reach it.
Possibly, but the criteria are specific rather than general: property tax or utility arrears that put the building on a lien sale list, a court-appointed receiver, foreclosure, a conveyance in lieu of foreclosure in the last two years, a senior mortgage in default, or heavy and immediate financial need beyond your control where you lack the debt capacity to comply and have exhausted other resources. A tight budget on its own is unlikely to meet it. Supporting documents can include financial statements and a letter from the owner explaining the hardship.
Yes — a two-year extension is available, and unlike an exemption you can apply for it from six months before your compliance date to six months after. For buildings like yours the qualifying reasons are natural disasters, goods and services shortages, buying the building at arm’s length within the previous twelve months, construction affecting at least 10 percent of the floor area, or financial hardship affecting cash flow. There is also a route that lets you benchmark on time and take extra time for the plan and maintenance program.
Setting your building up in ENERGY STAR Portfolio Manager and feeding it twelve consecutive months of whole-building energy data. Portfolio Manager calculates your weather-normalized energy use intensity — total energy divided by gross floor area, in kBtu per square foot per year. You then share the property with Commerce read-only, and the Clean Buildings Portal pulls the numbers through as Form C. Commerce recommends registering under a generic organizational account rather than an individual, so the login survives a change of staff or volunteers.
It’s a living document the owner reviews and signs every year. It names an energy manager, and records your energy use in Portfolio Manager, your target, and an annual comparison against it. It also documents changes in occupancy, operating hours and equipment; how you inform the congregation about efficient energy use; a training plan for whoever maintains the building; a capital plan for replacing failed equipment with ENERGY STAR rated models; and a contact list. The O&M program sits inside it.
Every system that uses energy — building envelope, HVAC, domestic hot water, refrigeration, lighting, controls, and power distribution. For each, you inventory the components, set a preventive maintenance schedule and task list, and define what unacceptable performance looks like. The plan names who performs each task and who authorizes it, and keeps records proving it’s running. Existing maintenance routines can usually be written up to meet this rather than started from scratch, and Commerce publishes a development tool for building the inventory.
A Qualified Energy Manager, through the Clean Buildings Portal, using a Secure Access Washington account. A QEM is an individual, not a firm — someone who has completed Commerce’s Tier 2 training and then meets any one of three routes: two years of commercial building operations or energy management experience, a supervised full-time fellowship or internship of at least six months that produced a successful compliance application, or Building Operator Certification Level I. Anyone meeting the broader Qualified Person definition also qualifies. Because an owner can fill any role in the standard, that can be a staff member rather than an outside consultant.
Still Not Sure?
Want the specifics for your building? Book a walkthrough and we’ll map it with you, or put your address into the Compliance Navigator for your tier, your deadline, and the property details behind them.