A lease clause helps only when accounts, authorizations, meter maps, permissions, transfers, data quality, privacy, and annual reporting stay under control.

Begin with the decision the data has to support

State why the owner and tenant need the record: whole-building benchmarking, a jurisdictional filing, building-performance planning, investor or lender reporting, cost allocation, efficiency work, emissions or water management, certification, tenant engagement, or verification of a capital project. Identify the properties, spaces, utilities, periods, required granularity, submission dates, intended recipients, and whether the need is recurring or tied to a specific transaction.

Assign accountable roles across ownership, asset management, property management, leasing, legal, sustainability, accounting, tenants, brokers, utilities, third-party data providers, and technical consultants. KOW can help define the technical data process and quality checks. Lease interpretation, privacy, consent, disclosure rights, and legal remedies remain with the parties and their counsel under the applicable lease and law.

Build the property, account, and meter map first

For each building and tenant space, record utility type, provider, account holder, account number or protected identifier location, meter and submeter identifiers, service address, start and end dates, units, interval or billing frequency, areas and equipment served, landlord or tenant payment responsibility, renewable or alternate supply, shared service, vacant-space treatment, and the system where data is stored. Connect tenant meters with base-building and owner-controlled meters so the intended whole-building boundary is testable.

Do not assume one account equals one space or that every meter belongs to the current tenant. Accounts may cover multiple suites, common areas, detached buildings, landlord equipment, prior occupants, separately managed operations, or service that changed during the reporting year. Compare utility records, bills, lease documents, meter schedules, field labels, drawings, submeters, Portfolio Manager records, and interviews. Log unknown service relationships rather than forcing them into the reporting boundary.

Write the obligation so the operating team can execute it

The lease or related agreement should address which energy, water, waste, demand, cost, renewable, or operational data is required; the period and frequency; acceptable format and delivery method; authorizations; direct utility or provider access; completeness and correction; the purpose and permitted use; confidentiality and aggregation; retention; costs; notice; cooperation with benchmarking or performance requirements; and what happens at provider, account, or occupancy changes. The appropriate language is transaction- and jurisdiction-specific and should be drafted or approved by counsel.

The 2026 Green Lease Leaders language guide identifies complete and accurate utility-data collection, owner or manager sharing, portal upload where applicable, reporting responsibility, and consequences of late or failed submission as important issues where benchmarking or performance rules apply. That guidance is not a substitute for the project lease. Use it to expose decisions that otherwise appear after execution, when a property manager discovers that the clause does not name the account, authorization, timing, or technical delivery path.

Select an access path for each utility and property

The practical route may be owner-paid bills, tenant bill delivery, a utility authorization, aggregated whole-building data, a utility portal, Portfolio Manager web services, a third-party bill-management platform, interval-data download, submeters, or a controlled manual process. EPA notes that utility offerings differ and may require property, meter, address, tenant, or separate portal steps beyond Portfolio Manager. Its utility map also shows that aggregation thresholds and consent conditions are provider-specific.

Define who creates the utility or platform connection, who accepts a share, which property and meters are included, the permission level, whether the provider can edit or exchange data, how failed imports and duplicate meters are handled, and who retains property-data-administrator control. Aggregated data can protect tenant privacy and complete a whole-building record while removing detail needed for tenant-specific analysis. Preserve the distinction and do not infer a tenant result from an aggregate building total.

Make leasing events controlled data handoffs

At letter of intent, lease, commencement, and move-in, confirm the required language, sustainability contact, utility providers, account setup, meter list, authorization forms, portal or Portfolio Manager connection, reporting calendar, initial data period, and tenant instructions. A form in the closing package is not complete until the receiving utility or platform accepts it and data begins to arrive for the correct meters.

Repeat the control at renewal, assignment, expansion, contraction, sublease, management change, utility or supplier change, vacancy, move-out, sale, and refinancing. Record final reads and bills, close the old reporting period, identify the successor account and contact, renew or terminate authorization, remove access that is no longer appropriate, transfer administrator responsibility, and verify the first complete period under the new arrangement. EPA’s Portfolio Manager sharing guidance distinguishes disconnecting a connection from removing property access; the handoff checklist should address both.

Operate one quality-controlled reporting loop

Review coverage by property, utility, meter, tenant, and month. Test for missing and overlapping periods, estimated or adjusted bills, unit and multiplier errors, duplicated imports, meter replacements, account gaps, demand-versus-consumption confusion, shared-service changes, renewable attributes, vacant periods, and changes in floor area, use, occupancy, and operating hours. Reconcile annual totals with bills or utility exports and preserve corrections with the source and date.

Maintain a dashboard or register showing required data, current authorization, last successful receipt, coverage through date, open exception, responsible party, reporting deadline, and final submission evidence. Use recurring landlord-tenant communication to resolve gaps and connect the record with operations and capital planning. Green leasing creates a framework for cooperation; the site-level process proves whether the data is actually complete, current, appropriately controlled, and useful.

Primary sources

Sources and technical references.

Source review current as of September 2, 2026.