Wednesday January 15, 2025
New York’s web of inspection requirements and energy regulations can severely complicate buidling operations. FirstService helps boards and building owners navigate complex housing law requirements like the Corporate Transparency Act, Local Law 11 (FISP) remediation, Local Law 97 emissions requirements, the Fair Chance for Housing Act, and more.From our in-house Compliance Department, here are the most critical compliance deadlines for New York City boards and building owners.
Local Law 11 (FISP) | Facade inspections
Buildings taller than six stories are required to perform facade inspections and any necessary repairs every five years. This now includes balcony and railing inspections, more comprehensive facade examinations, and updated reporting requirements. Buildings must also post a copy of the DOB “Wall Certificate,” which indicates the building’s filed facade condition (i.e., safe, SWARMP, or unsafe).- Sub-Cycle 10A opens 2/21/2025 and closes 2/21/2027 (Blocks 4, 5, 6, and 9)
- Sub-Cycle 10B opens 2/21/2026 and closes 2/21/2028 (Blocks 0, 7, and 8)
- Sub-Cycle 10C opens 2/21/2027 and closes 2/21/2029 (Blocks 1, 2, or 3)
An annual observation of the parapet of a building(s) must be performed in accordance with the requirements set by the DOB, separate from their Local Law 11 filing. The observation must include close-up inspections of the entire parapet which could be conducted from a fire escape or roof.
Should any hazardous or unsafe conditions be found, immediate measures must be taken to secure public safety until the condition can be remedied. This may include erecting a sidewalk shed, removing the unsafe condition, closing off the area with a fence, and/or installing safety netting.
All unsafe conditions must be corrected within 90 days from the notification to the DOB. Public protection must remain in place until the unsafe condition is remedied.
Read more from the Department of Buildings.
Local Law 31 | Lead-based paint inspections
The law requires apartment inspections using an x-ray fluorescence (XRF) analyzer by August 2021 if a child under the age of six resides in the unit or by August 9, 2025, for non-owner- occupied apartments.Learn more about lead paint inspections from our in-house Compliance Department.
Local Law 55 | Indoor allergen hazards inspections
The law requires boards and building owners to annually inspect apartments for the presence of mold, pests, and rodents, and also to respond to any complaints received directly from tenants or HPD.Read more from the Department of Housing Preservation & Development (HPD).
Local Law 69 | Bed bug reporting
The law requires annual filing of bedbug infestation and treatment reports with the HPD.Read more from HPD.
Local Laws 77 and 76 | Cooling tower inspections and certification
Local Law 77 established new rules for cooling tower maintenance, including initial registration, quarterly inspections, test results reporting, city and state portal management, and annual certification.Local Law 76 amended the administrative aspects of cooling tower compliance as it relates to documentation, submission, and availability of inspection results and certifications.
Since 2020, DOHMH requires a summertime hyperhalogenation to be performed between July 1st and August 31 of each year, which will further reduce the risk of legionella growth during the summer months.
Read more from the Department of Health (DOH).
Local Law 111
The law requires any doors providing access to apartments, hallways, and stairs to be self- closing. It also requires property owners to inspect, test, and document lead-based paint hazards. This includes completion of an x-ray fluorescence (XRF) analyzer test of all common spaces in residential properties by August 1, 2025.Fire Safety FAQ for NYC Residents
Local Law 126 | Parking structure inspections
Owners of parking structures are required to retain a Qualified Parking Structure Inspector (QPSI) to inspect the parking structure and file a condition assessment report with the DOB at least once every six years. Unsafe conditions must be repaired within 90 days of filing a condition assessment report. Once the work is finished, an amended report must be filed within two weeks.A parking structure does not include a garage with occupancy for fewer than three cars, nor an unenclosed or unattached parking lot.
The parking structure report and maintenance/repair deadlines are divided into cycles, which are further subdivided into three sub-cycles. The Community District in which the parking structure is located determines if the property falls into sub-cycle A, B, or C.
Sub-cycle filing and repair deadlines:
- Manhattan Community Districts 1-7
- January 1, 2022 - December 31, 2023
- Manhattan Community Districts 8-12
- January 1, 2024 - December 31, 2025
- All Brooklyn Community Districts
- January 1, 2024 - December 31, 2025
- All Bronx, Queens, and Staten Island Community Districts
- January 1, 2026 - December 31, 2027
Local Law 152 | Gas piping inspections
The law requires periodic inspections of gas piping systems in all buildings, with the exception of buildings classified in occupancy group R3. Inspections must be performed and submitted every four years based on the property’s Community District.Sub-cycle inspection deadlines:
- Community Districts 1, 3, and 10 in all boroughs
- January 1, 2024 – December 31, 2024
- Community Districts 2, 5, 7, 13, and 18 in all boroughs
- January 1, 2025 – December 31, 2025
- Community Districts 4, 6, 8, 9, and 16 in all boroughs
- January 1, 2026 – December 31, 2026
- Community Districts 11, 12, 14, 15, and 17 in all boroughs
- January 1, 2027 – December 31, 2027
Local Law 157 | Natural gas detectors
This law mandates the installation of natural gas detectors in residential buildings by May 1, 2025.Local Law 157: FAQ for Boards and Building Owners
Climate Mobilization Act (CMA) | Carbon emissions reduction, energy audits, and benchmarking
This bundle of laws sets emission caps on buildings. The goal is to achieve a 40% reduction in New York City gas emissions by 2030 and an 80% reduction by 2050. This regulation mandates measurable energy performance and will require retrofits in many buildings.Local Law 97 establishes a target for carbon emissions intensity on a per square foot basis for buildings based on their occupancy class. Data will be submitted along with the annual benchmark filing and converted to carbon intensity per square foot. Buildings that exceed their targets for reducing their carbon footprint will be penalized as of 2024.
Local Law 87 requires buildings over 25,000 square feet to perform periodic energy audit and retro-commissioning measures and submit an Energy Efficiency Report (EER) with the DOB.
Local Law 84 requires annual benchmarking of energy and water consumption.
Local Law 33 requires buildings larger than 25,000 square feet to display their energy efficiency grade near each public entrance.
Conflict of interest
The deadline for boards to distribute the conflict-of-interest reports is December 31. As a reminder, each year, cooperative and condominium buildings must disclose to their shareholders/owners all transactions in which a member of the board has a conflict of interest. Board members must receive a copy of Section 713 annually.Sexual harassment prevention training
Local Law 96 requires employers with 15 or more employees to conduct annual anti sexual harassment prevention training for all employees. Additionally, anti-sexual harassment posters must be placed in a conspicuous location and a prevention fact sheet must be distributed to all new employees.Read more from the NYC Commission on Human Rights.
Fire safety and emergency documents
FDNY Code has been amended to include the required distribution of several new fire safety documents including the NYC Emergency Preparedness Guide, Fire and Emergency Preparedness Annual Bulletin, and Emergency Preparedness and Evacuation Planning Checklist.Local Law 115 requires “Close the Door” notices to be posted on the public hallway side of stairwell doors, advising occupants to close all doors.
Local Law 103 requires the posting of hurricane evacuation notices advising residents of the building’s current evacuation zone designation along with instructions on how to locate the closest evacuation centers.
Local Law 10 requires buildings to confirm the installation of a fire safety notice on the inside of every apartment door and replace any decals that are damaged or missing. Compliance can be achieved by performing a physical inspection of each apartment or obtaining a signed certification from the resident confirming receipt and installation of such notice.
Fire Safety FAQ for NYC Residents
Sanitation reminders
- Residential buildings must place trash on the curb after 6PM in a secure container with lid, and no later than 12AM or after 8PM if placing bags directly on the curb.
- Businesses must place trash out one hour before closing in a secure container with lid or after 8PM if putting bags directly on the curb. This does not apply to waste collected from a loading dock.
- Separation of leaf and yard waste is now mandatory, as well as separation of food waste and food-soiled paper.
- Containerization applies to food-related businesses and chain stores as of late
- 2023.
- Curbside composting rollout to all boroughs in effect since October 2024.