The three-year licensed-verifier requirement is a recurring line item that many boards discover only when a compliance notice arrives. It is not the annual data upload; it is a separate professional engagement on a three-year cycle, and it should be in the budget and in the reserve calendar.

The data problem the state just solved

The historic obstacle to compliance in a condominium is that whole-building consumption has to be assembled from individually metered units, and an association has no right to its owners' usage data. Boards have chased individual authorizations, which fails at the first refusal and has to be redone as units turn over.

Illinois has now addressed this. The Utility Data Access Act in Public Act 104-0458, effective June 1, 2026, expressly names “the board, in the case of a condominium or cooperative ownership” as a data recipient entitled to aggregated usage data where the property meets the aggregation threshold — five or more residential and nonresidential accounts, in practice nearly every association.

Utilities must deliver requested data within 30 days, uploaded directly to ENERGY STAR Portfolio Manager or another approved format. That is precisely the benchmarking workflow.

The catch is timing: the Illinois Commerce Commission must open a rulemaking within 90 days of the effective date and adopt procedures within two years. So the right exists and the mechanism does not yet. The data request is realistic for the 2027 or 2028 cycle, not this one.

What Chicago has not done

Worth stating clearly, because it is the question boards ask. Chicago has published a Decarbonization Roadmap but, unlike New York's Local Law 97, has not adopted emissions limits tied to benchmarking data. There is no Chicago building performance standard at present.

So the current obligation is to measure and disclose, not to hit a target. A board planning capital work should nonetheless assume that benchmarking data is the baseline any future standard would be measured against — which is an argument for getting the numbers right now rather than filing whatever the platform will accept.

The other Chicago deadlines in the same season

Benchmarking sits alongside the facade ordinance's November 1 and December 1 filing deadlines for buildings 80 feet or taller, and annual fire-safety certification on the building's anniversary date under Municipal Code Chapter 13-78. For a large Chicago association these are three separate professional engagements on three different cycles, and no one is coordinating them but the board.

What to do now

Confirm the building's square footage against the 50,000 threshold, find out when the last licensed verification was done, and put the next one in the budget. If the June 1, 2026 filing was missed, file late rather than not at all — the penalty structure is per-day.

What to watch next

The ICC rulemaking on utility data access, and any move from the Decarbonization Roadmap toward an actual performance standard.