NYC Lead-Paint Rules for Rental Building Owners

Which buildings are covered?

HPD’s guidance focuses on buildings built before 1960, and on buildings built between 1960 and 1978 where the owner knows of lead-based paint. In covered buildings, owners must presume that paint is lead-based unless testing shows otherwise and HPD grants an exemption. NYC’s legal standard for lead-based paint is 0.5 mg/cm², lowered from 1.0 mg/cm² on December 1, 2021.

Annual notices and investigations

Owners of covered multiple dwellings send an annual notice to find out whether a child under six lives in, or routinely spends 10 or more hours a week in, each unit. HPD’s bulletin describes delivering notices between January 1 and January 16 and following up with non-responding units. In units with young children and in common areas, owners must investigate painted surfaces and properly repair peeling paint.

XRF paint testing (Local Law 31 of 2020)

Owners of covered buildings were required to have an EPA-certified inspector or risk assessor — independent of the owner and of any remediation firm — test painted surfaces in rental units and common areas with an XRF device by August 9, 2025. Owner-occupied units are not required to be tested. If testing found no lead-based paint, HPD encourages owners to apply for a lead-free exemption.

What happens after a positive result depends on the paint’s condition and occupancy. HPD’s FAQ says peeling lead-based paint in a unit with a child under six requires immediate action by an EPA-certified abatement firm, while intact paint must be monitored, and positive door and window friction surfaces must be abated at turnover.

Turnover requirements

When a unit in a covered building becomes vacant, HPD requires specified work before re-renting — including removing lead-based paint from friction surfaces of doors and door frames, addressing window friction surfaces, making floors, sills, and window wells smooth and cleanable, and remediating lead-based paint hazards.

Abatement timelines (Local Law 123 of 2023)

HPD’s January 2026 bulletin summarizes Local Law 123 abatement deadlines for pre-1960 multiple dwellings as the earliest of:

• Turnover of the dwelling unit
• July 1, 2027, for units where a child under six lived as of January 1, 2025
• Three years after a child under six moves into a unit, if that happens after January 1, 2025

Recordkeeping and lease notices

Owners must keep records of notices, investigations, testing, and repairs for at least 10 years, and provide required lead notices and the “Lead Paint Hazards in the Home” pamphlet at lease signing and renewal.

Official sources

• HPD – Lead-Based Paint
• HPD – Paint Testing Requirement and Exemptions
• HPD – January 2026 Lead Bulletin for Property Owners (PDF)
• Local Law 123 of 2023 (PDF)
• HPD – Turnover and child-occupied unit requirements

Questions about your building? Information for landlords and property managers.