The Midwest Compliance Map is Changing: New Energy Mandates in IL, WI, and MN

Energy Benchmarking
Written By Kevin Sheehan

If you own or manage buildings across the Upper Midwest, keeping track of energy reporting regulations used to be a city-by-city headache. In 2026, the landscape is shifting toward state-level mandates and stricter "action-oriented" requirements.

While Chicago owners are focused on the immediate January 15, 2026 benchmarking deadline, their counterparts in Wisconsin and Minnesota are facing entirely new compliance hurdles this year. The era of voluntary energy disclosure is effectively over; across the region, we are seeing a rapid transition from simple reporting to mandatory performance.

Here is the breakdown of what is happening in our neighboring jurisdictions and how it affects your portfolio.

1. Minnesota: The "Statewide" Takeover

For years, navigating compliance in Minnesota meant checking specific ordinances in Minneapolis, St. Paul, Edina, and St. Louis Park. That is changing.

Minnesota has rolled out a Statewide Large Building Energy Benchmarking law that supersedes many local municipal programs. In fact, cities like St. Paul and Bloomington have discontinued their local programs to align with the state.

  • The New Deadlines:

    • June 1, 2025: Compliance deadline for buildings >100,000 sq. ft.

    • June 1, 2026: Compliance expands to buildings >50,000 sq. ft.

  • The Catch: This applies not just to the Twin Cities metro (Hennepin, Ramsey, Dakota counties, etc.) but to any city with a population over 50,000.

  • Edina is Still Special: Watch out for Edina. They retain their "Efficient Buildings Ordinance," which goes a step further. If your building is a "low performer" (low ENERGY STAR score), you are required to perform an energy assessment. This is a precursor to full Performance Standards (BEPS).

2. Wisconsin: Madison Moves to "Tune-Ups"

While Minnesota is focused on data coverage, Madison, WI is quietly implementing one of the most aggressive "action" mandates in the Midwest.

Under the Madison Building Energy Savings Program (BESP), simply reporting your data is no longer enough.

  • Benchmarking Deadline: June 30, 2025, for buildings >50,000 sq. ft.

  • Mandatory Tune-Ups: This is the game-changer. Starting October 2025, large buildings must complete a "Tune-Up" (essentially a retro-commissioning process) every four years. This requires a qualified engineer to physically inspect the building’s systems—HVAC scheduling, sensor calibration, and setpoints—and certify that "low-cost/no-cost" fixes have been implemented.

Milwaukee Update: Milwaukee also joined the fray in July 2024 with its own benchmarking ordinance for buildings over 50,000 sq. ft., further solidifying the I-94 corridor as a regulated zone for building energy.

3. Chicago: The Enforcement Pivot

Back home in Chicago, the deadline extension for the Building Energy Benchmarking Ordinance to January 15, 2026 offers a breathing room, but the City is using this time to scrutinize data quality.

  • Verification is Key: With Evanston passing a true Building Energy Performance Standard (BEPS) and the State of Illinois eyeing similar moves, Chicago's data verification is becoming the "baseline" for future carbon caps. If you submit bad data now, you are setting yourself up for expensive penalties later.

What This Means for Your Portfolio

The trend across IL, WI, and MN is unified: The "Clipboard Audit" is dead.

Compliance is no longer an administrative task for an intern. Madison requires engineering tune-ups; Edina requires technical assessments; Minnesota requires statewide data rigor.

  • If you have assets in Madison: You need to schedule your Tune-Up now before the October rush.

  • If you have assets in the Twin Cities: You need to transition your reporting from the city portals to the new State system by June 1.

  • If you have assets in Chicago: You need to ensure your benchmarking submission is verified and accurate to protect against future BEPS liabilities.

We Can Handle the Region: At Sheehan Engineering, we carry the licenses and credentials to manage compliance across these state lines. Whether you need a Tune-Up in Madison, a verification in Chicago, or a portfolio-wide strategy for Minnesota, we provide a single point of contact for complex engineering compliance.

Contact us today to simplify your Midwest compliance strategy.

Kevin Sheehan