NYC lead paint laws: What owners need to know in 2026/2027

Which buildings are covered by NYC lead paint laws?

NYC lead paint laws generally apply to multifamily residential buildings built before 1960. They can also apply to buildings built between 1960 and 1978 if the owner knows lead-based paint is present. The NYC Department of Housing Preservation and Development (HPD) says owners of these buildings must presume paint is lead-based unless testing is negative and HPD grants an exemption based on testing and any required abatement work.

The new laws make New York City’s lead paint standards the strictest in the nation and include complex requirements for compliance. Our in-house compliance experts have supported hundreds of New York City building owners and answered the most frequently asked questions about lead paint inspections, filing requirements, and avoiding fines.
 

What counts as lead-based paint in NYC?

NYC lead paint laws define lead-based paint as paint or similar surface coating containing 0.5 milligrams of lead per square centimeter or greater, as determined by laboratory analysis or X-Ray Fluorescence (XRF) analyzer (Local Law 66).
 

Annual notices

Owners of covered multiple dwellings must deliver annual lead-based paint notices to tenants between January 1 and January 16 and collect completed notices by February 15. The notice asks whether a child under six routinely spends 10 or more hours each week in the unit. Owners should keep proof of delivery and tenant responses with their compliance records. Learn more in our guide to NYC tenant rights.
 

What happens if tenants do not respond?

If the owner does not receive the completed notice from the tenant and cannot determine based on these follow-up investigations whether there is a child under six, the owner must also notify the NYC Department of Health and Mental Hygiene (DOHMH) in writing that no notice has been received back from the tenant.
 

Annual investigations

Annual investigations are required in covered units where a child under six resides, and in building common areas when a child under six resides in the building. HPD explains that a lead-based paint hazard can include peeling or disturbed paint, lead dust from friction surfaces, and chewed painted surfaces in covered buildings. If peeling paint is reported, found during investigation, or cited by HPD or DOHMH, the owner must properly repair the hazard.
 

New York City’s lead paint inspection laws

Key NYC lead paint inspection laws include: 

• Local Law 1 – Property owners must provide annual notices to tenants about lead-based paint hazards, conduct required annual visual investigations, and properly correct lead-based paint hazards where required. These notices and repair records must be maintained for at least 10 years.
   
• Local Law 31 – Requires independent EPA-certified inspectors or risk assessors to conduct XRF tests in covered apartments. The law mandated that these tests be completed by August 9, 2025, so any required testing that was not completed should now be treated as overdue. Owners must also maintain testing records for at least 10 years and provide them to HPD when requested.
   
• Local Law 66 – Lowers the threshold that defines paint or similar surface coating as “lead-based” from 1.0 mg/cm² to 0.5 mg/cm².
   
• Local Law 111 – Expands Local Law 31’s XRF testing requirements to include common areas (i.e. hallways, an amenity space, residential lobby, etc.).
   
• Local Law 122 – Requires owners to provide records of annual notices, investigations, and XRF testing to HPD within 45 days of certain HPD notices following lead-based paint hazard or turnover violations.
   
• Local Law 123 – Owners must address lead-based paint hazards within apartments upon turnover, or by July 1, 2027 for covered units where a child under six resides as of January 1, 2025, or within three years after a child under six begins residing there.
   
• Local Law 127 – Mandates that turnover violations – violations that occur when an apartment changes tenants – are a criterion for selecting buildings for audit. Data on blood lead levels in certain areas collected by the DOHMH will also be used as applicable criteria.

What are the fines for failing to follow NYC lead paint laws?

In January 2024, HPD levied over $150,000 in civil penalties against a property owner for violations across its portfolio. As NYC lead paint laws increase the cost of noncompliance, it’s important to be aware of how these violations fit into the landscape of existing penalties:

• Failing a lead paint inspection – Violations involving deteriorated or peeling lead paint are considered a Class C violation under Local Laws 1 and 111.
   
• Failing to correct violations – May result in fines of $250 per day, up to $10,000, for Class C lead-based paint hazard violations under Local Law 1. Certain audit-based failures to complete required turnover work or required lead-paint work in child-occupied units may result in penalties of up to $1,500 under Local Law 123.
   
• Failing to produce annual notice, investigation, and related lead records when HPD requests them – May result in fines of $1,000 to $5,000 per violation.
   
• Failing to complete required XRF testing – May result in fines of $1,500 per unit or common area where compliance can’t be verified.
   
• Failing to maintain or produce annual notice and investigation records – May result in fines between $1,000 and $5,000 per violation and can include a Class C violation under NYC’s lead-paint recordkeeping requirements.

Lead abatements can unlock exemptions for NYC building owners

Owners of pre-1960 buildings may apply for exemptions from some Local Law 1 requirements by proving that their unit, common area, or building area is free of lead-based paint, or that their building has been made “lead safe.” There are two types of exemptions:

• Lead Free exemptions are available to property owners who can show that their unit, common area, or building area is lead-free via their initial mandated XRF tests, or that they have since permanently eliminated the source of the lead through an EPA-certified abatement firm.
   
• Lead Safe exemptions are granted when lead has been safely contained or encapsulated using approved methods such as approved encapsulants or containment/enclosure. Ongoing monitoring and maintenance of the contained or encapsulated surfaces are required to maintain this exemption status, along with any periodic monitoring or assessment requirements in the HPD-approved monitoring plan.

Exemptions already in place under the 1.0 mg/cm² threshold remain in effect until unit turnover.
 

How can your manager support compliance with NYC lead paint inspection and abatement laws?

Navigating the web of NYC lead paint laws and regulations governing multifamily housing can be quite a challenge. Our dedicated Compliance Department uses InCheck by SiteCompli, a virtual platform that tracks the status of building inspections, permit expiry, violations, and complaints. This means our property managers have more time to focus on building operations, tenant requests, and big-picture goals.

Here are a few ways we use InCheck in the buildings we manage:

• Automatically track new laws, regulations, and deadlines
   
• Gather building-specific compliance data to schedule inspections and repairs
   
• Generate required logs for HPD, FDNY, and the DOB
   
• Annual safety notice mailings to residents on behalf of ownership
   
• Scheduling combined inspections to reduce inconvenience for residents
   
• Keeping stakeholders informed with real-time updates tailored to their roles and responsibilities

This approach protects your building and frees our property managers to focus on enhancing your day-to-day operations.

Compliance questions? Contact a member of our team today.

This information is provided for general informational purposes only and is not intended to constitute, and should not be relied upon as, legal, regulatory, financial, or operational advice, or as a representation or guarantee of any specific services, capabilities, or outcomes. Property management needs, regulatory requirements, market conditions, and available services vary by jurisdiction, property type, and community. FirstService Residential provides services through locally based affiliates and associates, and services and results may vary by community, region, contractual terms, and applicable law.