What NYC Property Owners Need to Know
Local Law 123 of 2023 introduced significant new requirements for lead-based paint remediation in certain New York City residential buildings. For property owners and managers, understanding the timeline is critical—not only because of the July 1, 2027 deadline, but because some obligations can be triggered earlier by apartment turnover or when a child under six begins residing in an occupied apartment.
The law focuses on pre-1960 multiple dwellings where a child under six resides and expands the lead-based paint work that must be completed in applicable apartments.
Waiting until 2027 to begin planning can create unnecessary pressure. Property owners should understand which deadline applies to each apartment and determine what testing, documentation, inspection, and remediation work may be required.
What Is Local Law 123?
Local Law 123 amended New York City's lead-based paint requirements to require additional remediation work in certain dwelling units where a child under six resides.
The law requires applicable owners to address lead-based paint hazards and certain lead-painted friction surfaces on doors, door frames, windows, and related components.
Under the law, the required work must occur upon the earliest applicable trigger, rather than automatically waiting until July 1, 2027.
The three major timing triggers are:
- Apartment turnover
- July 1, 2027, for applicable units where a child under six resided as of January 1, 2025
- Within three years after a child under six begins residing in an applicable occupied unit after January 1, 2025
Understanding which of these situations applies to a particular apartment is one of the most important parts of Local Law 123 compliance.
September 1, 2024: Local Law 123 Takes Effect
Local Law 123 was enacted in 2023 and took effect on September 1, 2024.
The law amended the City's Administrative Code to expand the circumstances under which lead-based paint remediation must be completed in applicable dwelling units.
Rather than limiting the more extensive turnover-related work to the point when an apartment becomes vacant, the law establishes additional requirements for occupied units where a child under six resides.
This means property owners need to look beyond traditional apartment turnover schedules and understand the status of occupied units as well.
January 1, 2025: The First Major Reference Date
January 1, 2025 is an important date under Local Law 123.
If a child under six resided in an applicable dwelling unit as of January 1, 2025, the required work must generally be completed by July 1, 2027, unless an earlier trigger applies.
That gives owners a defined period to identify affected apartments, review existing lead documentation, determine what work is necessary, and plan for compliance.
Owners should not wait until 2027 to start this process.
A property with multiple apartments may have different compliance timelines depending on when children under six began residing in individual units.
January 1–16: Annual Notice Requirements
Local Law 123 operates alongside existing NYC lead-based paint requirements.
Every year, applicable property owners must deliver the required Annual Notice between January 1 and January 16 to determine whether a child under six routinely resides in a dwelling unit.
The completed notice must be collected by February 15.
A child is generally considered to reside in an apartment when the child routinely spends 10 or more hours per week there.
This annual process is important because it helps property owners identify which apartments may be subject to additional lead-related requirements.
Owners should maintain documentation showing:
- When the Annual Notice was delivered
- Which tenants received it
- When responses were received
- Which units have a child under six residing there
- Any required follow-up investigation
- Any repairs or remediation performed
The Annual Notice should not be treated as simply another piece of paperwork. It can provide information that affects the compliance timeline for a particular apartment.
July 1, 2027: The Major Local Law 123 Deadline
The most important date for many property owners is:
July 1, 2027
By this date, required Local Law 123 work must be completed in applicable dwelling units where a child under six resided as of January 1, 2025, unless the required work was already triggered and completed earlier.
The work includes requirements related to:
- Remediation of lead-based paint hazards
- Correction of underlying defects associated with those hazards
- Making applicable bare floors, window sills, and window wells smooth and cleanable
- Removing or permanently covering lead-based paint on friction surfaces of doors and door frames
- Removing or permanently covering lead-based paint on friction surfaces of windows
- Installing appropriate replacement window channels or slides where applicable
HPD confirms that these requirements are part of the Local Law 123 turnover-related requirements.
Why owners should not wait until July 2027
A deadline does not mean the work should begin at the last minute.
Large properties may have multiple apartments requiring evaluation and remediation. Work may involve:
- Lead inspections
- XRF testing
- Hazard identification
- Scope development
- Tenant communication
- Contractor scheduling
- Safe work procedures
- Remediation or abatement
- Clearance or documentation
- Recordkeeping
Beginning the process early gives owners more time to identify problems and complete the necessary work.
What Work Does Local Law 123 Require?
The required work goes beyond simply repairing visible peeling paint.
Depending on the circumstances, owners may need to address:
Lead-Based Paint Hazards
All applicable lead-based paint hazards and underlying defects must be remediated.
Doors and Door Frames
Lead-based paint on friction surfaces must be removed or permanently covered.
Windows
Lead-based paint on applicable window friction surfaces must be removed or permanently covered, or appropriate replacement window channels or slides must be installed.
Floors and Window Components
Applicable bare floors, window sills, and window wells must be made smooth and cleanable.
This is important because friction surfaces can generate lead-containing dust even when the paint does not appear visibly deteriorated.
How Lead & Mold Detectives Can Help
Local Law 123 compliance requires more than knowing the deadline.
Property owners need to understand which apartments are affected, what lead-based paint conditions exist, what work is required, and when that work must be completed.
Lead & Mold Detectives can help property owners navigate the lead inspection and compliance process, including lead-based paint testing and identifying conditions that may require remediation.
Planning early can help property owners avoid last-minute compliance issues and make sure required work is addressed within the applicable timeline.
Don't Wait Until July 1, 2027
If your NYC property may be subject to Local Law 123, now is the time to review your lead-based paint records, identify affected apartments, and determine your compliance timeline.
Need help with Local Law 123 compliance or lead-based paint testing?
Call Lead & Mold Detectives at 516-407-1111
Email: sales@leadandmold.com
This article is provided for general informational purposes and is not legal advice. Property owners should review the applicable NYC laws and HPD requirements for their specific property and circumstances.