NYC Lead Paint Law (Local Law 1): Landlord Duties

If you rent out an apartment in a NYC building built before 1960, Local Law 1 of 2004 requires you to presume the paint is lead, send a lead notice every January, inspect every year where a child under 6 lives, do specific lead work every time a unit turns over, use certified contractors and keep records for 10 years. Buildings built from 1960 through 1977 are covered too if you know there is lead paint.

HPD enforces the law, and almost all of its lead violations are Class C, immediately hazardous. Below is each duty in order, with the dates and thresholds HPD publishes, and a checklist you can work through.

Who is covered

HPD says Local Law 1 applies to owners of:

• Multiple dwellings (3 or more units) built before 1960
• Tenant-occupied units in one- and two-family homes built before 1960
• Buildings built from January 1, 1960 to January 1, 1978 where the owner knows there is lead-based paint
• Co-op and condo units not occupied by the owner or the owner's family; coordinate with the board on common areas

The starting assumption is that paint in these buildings is lead-based. That presumption only goes away if a certified inspector tests the surfaces and HPD grants an exemption. Check the year built for any address on Roofy.

Duty 1: the annual notice

1. Jan 1–16

   Deliver the Annual Notice to every unit

   Use an HPD-approved form, in at least English and Spanish, in duplicate, and say how to return it.

2. By Feb 15

   Collect completed notices

   List units that did not respond and notify the Health Department (DOHMH) in writing. Keep a copy.

3. After Feb 15

   Inspect non-responding units

   If you don’t know whether a child under 6 lives there, inspect at a reasonable time with reasonable notice.

4. Feb 16–Mar 1

   Report failed access

   If you made a reasonable attempt to get into a unit in this window and could not, notify DOHMH in writing.

At lease signing and renewal, new and renewing tenants also get the Lease/Commencement of Occupancy Notice and the city's Lead Paint Hazards in the Home pamphlet. In buildings with 3 or more units, the window guard notice can be combined with the lead notice (see window guard rules for landlords).

Duty 2: yearly investigation where a child under 6 lives

Once you know a child under 6 resides in a unit, you must do a visual investigation at least once a year. HPD also expects one when a tenant complains of peeling paint, when conditions could create a hazard, or when a notice isn't returned. The check covers:

• Every painted surface in every room, including closets and cabinets
• Peeling or chipping paint, chewable surfaces, friction and impact surfaces, and deteriorated subsurfaces
• Common areas such as hallways, stairwells and lobbies, if a child under 6 lives in the building

You don't need a professional for the visual check, though HPD strongly recommends HUD's visual assessment training. Give the tenant a copy of the results and keep your notes.

Duty 3: turnover work

Before a new tenant moves into a vacant unit, HPD requires you to:

• Fix all peeling paint and the defects behind it (at minimum wet scrape and repaint, and fix leaks)
• Remove lead paint from chewed surfaces, or cover them with an approved hard encapsulant
• Remove lead paint from friction surfaces on all doors and door frames, and abate the required window friction surfaces
• Make all bare floors, windowsills and window wells smooth and cleanable
• Do all of it with safe work practices, then certify it on the lease notice you give the new tenant

The same work is required in occupied units where a child under 6 lives, even without visible peeling paint. HPD gives these deadlines: by July 1, 2027 for units where a child under 6 lived as of January 1, 2025, and within 3 years of learning that a child under 6 started living in a unit after that date. A missed friction-surface job must be done at the next turnover or sooner.

Duty 4: safe work practices and certified firms

No dry scraping. Use plastic sheeting on floors and between work and non-work areas, and clean daily with wet mopping and HEPA vacuuming. Check each contractor's EPA certificates before work starts and keep copies.

Duty 5: one-time XRF testing

Local Law 31 of 2020 added a one-time test of every unit and common area by an independent EPA-certified inspector using an XRF device. The deadline was August 9, 2025, or within one year after a child under 6 moves in, if that came first. If you haven't done it, read the XRF testing deadline guide now; HPD penalties are $1,500 per unit or common area.

Duty 6: records for 10 years

Keep proof of notice delivery, returned notices, investigation results, turnover work, safe work documentation, dust clearance results, contractor certificates and XRF reports for at least 10 years. HPD can audit you with a Record Production Order, and you have 45 days to respond. Missing or incomplete records lead to Class C violations and a civil penalty of $1,000 to $5,000. When you sell, the records go to the buyer.

What lead violations look like in HPD data

In the 12 months from October 1, 2025 through September 30, 2026, HPD issued 20,641 violations citing the lead sections of the Housing Maintenance Code (§27-2056). The most common types:

You can see any building's open lead violations on its Roofy page; see HPD violation status codes to read them, and how to certify corrections to clear them.

Your Local Law 1 checklist

Tick off each duty for the building. Progress is saved in this browser only.

Plan the year with the landlord compliance calendar, and make sure your HPD registration is current.