New Energy Code Enforcement Could Delay Your Project
As of this spring, the energy code moved controls to the front of the project. Is your seat in the channel ready?
By Geoff Marlow
Most of the lighting channel is about to get caught flat-footed by the new energy code cycle. On March 30, 2026, New York City began enforcing its 2025 Energy Conservation Code and the companion 2025 NYC ASHRAE 90.1 standard. Every complete application filed on or after that date must comply.
At nearly the same moment, ASHRAE and the IES published the national ANSI/ASHRAE/IES Standard 90.1-2025, incorporating 105 addenda across the standard. For lighting, the new edition lowers power allowances and strengthens control requirements. And the Department of Energy’s clock is running: states are required to adopt a commercial code at least as stringent as 90.1-2022 by mid-2026 or explain why they cannot.
Three code events, one direction. Lighting controls are no longer a compliance check performed after the layout is set. They are moving to the front of the project, into schematic design, where specifications get written and manufacturers get chosen. This is not a story about one seat in the channel. It is a story about how pressure applied at the specification stage transmits through every seat downstream, and about who converts that pressure into position.
First, Untangle the Names
A quick clarification will save your team embarrassment in front of a specifier. New York City’s “2025 NYC ASHRAE 90.1” is not the same document as the national 90.1-2025 standard. The city’s version is built on the 2025 Energy Conservation Construction Code of New York State, which incorporates the 2024 IECC and ASHRAE 90.1-2022 with state and city amendments. The national 90.1-2025 edition is the newly published model standard that jurisdictions will begin adopting over the coming code cycles.
That distinction matters for compliance paperwork. It does not change the strategic picture. Whether a project sits under New York’s amended 2022 baseline today or under the national 2025 edition two years from now, the trajectory is identical: lower power allowances, more granular control zoning, more daylight response, faster shutoff, and documentation demands that arrive earlier in the project. New York is not an outlier. It is a preview.
What Actually Changed
The national 90.1-2025 edition defines where every adopting jurisdiction is headed, so it is worth knowing the direction of travel even if your market has not adopted it yet.
Interior lighting power allowances moved largely downward again. Published Building Area Method examples show reductions of 5 to 10% compared to the 2022 edition, with warehouses a notable exception. Exterior allowances were significantly reduced, in both base allowances and tradable surfaces.
Occupancy sensing got faster and finer. The standard shutoff window tightened from 20 minutes of vacancy to 15. Open offices larger than 300 square feet now require occupancy sensors zoned at an average of 600 square feet per sensor, with no zone exceeding 900 square feet, and a sequence of operations that holds unoccupied zones at 20% power or less. That is not a wall switch and a ceiling sensor. That is a networked system with a programmed sequence — and it must be designed, not field-adjusted.
Daylight harvesting expanded. Secondary sidelit zones, the areas one step back from the window line, now require independent daylight-responsive control when general lighting in the zone reaches 75 watts. Sidelit dimming must reach below 10% of full power plus off, where the prior edition set the threshold at 20%.
The details keep pointing the same way. Exterior occupancy-based reduction zoning shrank from 1,500 watts per control to 600. Hotel card-key controls no longer satisfy the guestroom shutoff requirement. The standard’s scope now extends to lighting on sites independent of a building. None of these changes is dramatic alone. Together they describe a standard that assumes networked, zoned, sequence-driven control as the baseline condition of a commercial building.
Why One Code Change Ripples Through Six Seats
Here is the mechanism worth understanding. Under prior editions, controls could be resolved late, as a compliance exercise after the layout was set. The 2025 requirements make that sequence unworkable. Zoning granularity, secondary daylight zones, and programmed sequences of operation must be resolved while the reflected ceiling plan is still fluid. Compliance has become a schematic design task.
When a decision moves earlier in a project, everyone connected to that decision moves with it or loses influence over it. The specifier needs compliance answers at schematic design. The manufacturer must therefore have documentation ready at project entry, not upon request, and the rep who carries it gets pulled into the design conversation earlier. The distributor inherits a bill of material that is now a system rather than a fixture list, and the contractor inherits an installation that must pass functional testing rather than a visual inspection. The owner pays for all of it, operates all of it, and in performance-law markets answers for all of it. One requirement, six seats, and the sequence in which each seat adapts determines who holds leverage. What follows is an honest look at each.
Specifiers: The Pressure Starts Here
The relevance is direct. Controls compliance must be resolved during schematic design, not at submittal — and firms that treat it as a check-the-box task at the end will face reworked layouts, rebid controls packages, and missed deadlines. The firms that internalize the new sequencing gain something else: standing to own the controls narrative on the project rather than ceding it to whoever shows up at value engineering.
Actions: Build the 90.1-2025 zoning and daylight logic into schematic design templates now, before your local jurisdiction forces it. Decide which manufacturers and agencies can support space-by-space documentation at project entry, and shortlist accordingly. Treat sequences of operation as a design deliverable, not a submittal afterthought.
Manufacturers: Documentation at Entry or Price Competition at Exit
A manufacturer whose compliance data exists “upon request” is a manufacturer whose products get value-engineered later, on price. A manufacturer who arrives at schematic design with space-by-space compliance data, integration details, and a commissioning story becomes easy to specify and hard to substitute. Controls integration is becoming a primary selection criterion, in many cases outweighing raw efficacy because efficacy differences among quality products are now small while integration failures are expensive and visible.
Actions: Publish compliance documentation, sequences of operation, and integration guides before specifiers ask. Train regional sales teams on the code, not just the catalog. Equip your rep network with the schematic-stage toolkit, because they are your presence in the room you cannot be in. If your compliance story is still the phrase “90.1 compliant” on a spec sheet, you are planning to compete on price.
Rep Agencies: Front Door or Back Door
Agencies carrying credible controls lines now have a legitimate reason to be in the first design conversation. This is no longer just about selling fixtures; it is about providing the technical scaffolding that makes the project viable. Agencies without a controls story are being cut from early-stage meetings before scope is set. If you cannot speak the language of zoning limits, daylight thresholds, and sequences of operation, you are effectively invisible to the design team.
Actions: Audit your line card against the new standard honestly and fill the controls gap with a credible line, not a placeholder. Develop at least one controls-fluent specialist the design community knows by name. Position the agency as the compliance translator between the specifier’s intent and the distributor’s bill of material. Front door or back door. Choose your line card accordingly.
Electrical Distributors: The Counter Is the Early Warning System
The questions are already arriving at the counter and the quotations desk, and they will accelerate as adoption spreads state by state. A bill of material missing required control components does not fail quietly. It fails at inspection, and it comes back as a return, a rework, and a relationship problem. The distributor who catches the gap at quotation protects the contractor; the one who does not owns part of the fallout.
Actions: Give inside sales and quotations teams enough code fluency to recognize an incomplete controls package. Build quotation packages that bundle fixtures, sensors, and controls as compliant systems rather than line items. Know which utility rebate programs reward the same networked controls the code now mandates because the code requirement and the rebate opportunity are frequently the same scope of work. That turns a compliance conversation into a payback conversation, and payback conversations win orders.
Contractors: The Cost of Late Discovery Lands on You
The contractor absorbs the labor cost when a project fails energy inspection. Pulling fixtures, adding sensors that should have been in the original scope, and reprogramming sequences are unbudgeted hours, and the certificate of occupancy waits on all of it. Functional testing of lighting controls has been part of 90.1 compliance for over a decade, but the new sequences of operation make it materially harder to pass. A system that is installed correctly, but programmed incorrectly, still fails.
Actions: Verify at bid time that the controls scope matches the code edition governing the permit and price the commissioning and functional testing hours explicitly rather than absorbing them. Ask the distributor and rep for the sequence of operations before rough-in, not after. Flag incomplete controls scope in writing during bidding; it protects your margin and positions you as the contractor who catches problems before they are buried in the ceiling.
Building Owners: You Operate What Everyone Else Designed
Owners inherit the consequences of every decision above. A building designed to the new standard carries networked, zoned, daylight-responsive lighting whether or not anyone plans to manage it. Handled well, that infrastructure lowers operating cost, supports demand response participation and – in markets with building performance laws, such as New York City under Local Law 97 – becomes part of the compliance answer rather than part of the problem. Handled poorly, it becomes an expensive system nobody on staff understands, drifting out of calibration within a year of occupancy.
Actions: Require the sequences of operation and commissioning documentation as a turnover deliverable, in writing, in the contract. Ask your design team early which code edition governs and what the controls system will require of your operating staff. Capture available utility incentives during design, when the scope can still flex, not after. The owner who engages at schematic design pays once. The owner who engages at punch list pays twice.
Where the Interests Converge
Notice what every one of these action lists has in common: each seat’s protection depends on information from the seat upstream arriving earlier than it used to. The specifier needs the manufacturer’s data at schematic design. The rep needs that documentation in hand before the first design meeting. The distributor needs the specifier’s controls intent at quotation. The contractor needs the sequence of operations at rough-in. The owner needs the commissioning record at turnover. The code did not just raise technical requirements, it raised the penalty for information arriving late, at every handoff in the channel.
That is the overlap — and it is also the opportunity. The channel players who move documentation and coordination earlier will not just comply; they will become the partners everyone else needs to comply. Code transitions create temporary, high-value advantages, and most of the market will wait for adoption to force the issue. New York’s enforcement date was the starting gun, and the DOE adoption deadline ensures the race spreads state by state. Define the baseline — don’t just meet it.
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About the author
Geoff Marlow is President of Marlow Advisory Group, a strategic advisory firm serving manufacturers, distributors, rep agencies, and investors in the lighting and electrical channels.
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