If you own a building in New York City, you already know that lead paint compliance is no joke. But with Local Law 122 now in full effect, the rules just got stricter — and a lot of landlords are getting caught off guard.
I want to break this down in plain English so you know exactly where you stand.
What Changed?
Local Law 122 kicked in on September 1, 2024. Here is the big change — it used to be enough to just fix a lead paint problem when HPD came knocking. Now that is not enough anymore.
If HPD issues a lead paint hazard violation or a turnover violation against your property, you must now hand over your annual notice and investigation records to HPD within 45 days. Starting August 2025 you also have to provide your XRF testing records at the same time.
In other words — HPD does not just want to see that you fixed the problem. They want to see proof that you have been doing the right thing all along.
What Are Annual Notice Records?
Every January between the 1st and 16th, you are required to send every tenant an Annual Notice asking if a child under 6 lives in or regularly spends time in the apartment. Your tenant has until February 15th to send it back.
If they do not send it back, you cannot just ignore it. You need to follow up between February 16th and March 1st, document your attempts to reach them, and if you still cannot get a response, notify the NYC Department of Health in writing.
Every single one of these notices, responses and follow-up attempts needs to be kept on file for 10 years. Not 5 years. Not whenever you feel like it. 10 years.
What Happens If You Do Not Have Your Records?
This is where landlords are really getting hurt. Your building can be in perfect condition — no peeling paint, no violations — but if HPD asks for your records and you cannot produce them, you are getting a violation anyway.
If you are missing records, there is a path to dismissal but it will cost you. You can submit at least 3 consecutive years of records and pay $1,000 for every missing year of the required 10. That adds up fast.
The Bottom Line
Start pulling your records together today. If you are behind on your annual notices or missing documentation from previous years, get organized now before HPD shows up at your door.
And if you have received an HPD lead paint violation and need help navigating the compliance process, call NY Lead Paint Experts at 646-632-7154. We have been helping NYC landlords deal with exactly these situations for over 10 years. The consultation is free and so is the estimate.