NYC Lead-Based Paint Compliance Deadline: August 9, 2025
Let’s talk straight. If you own or are thinking of buying an older apartment in New York City, there’s a big deadline on the horizon—and it’s not optional. By August 9, 2025, lead-based paint testing will be required in thousands of residential buildings.
This isn’t just another compliance rule. It could affect your deal, your timeline, or your bottom line. Whether you’re selling a pre-war co-op or looking to rent out a brownstone, now’s the time to pay attention.
Who Needs to Follow This Law?
Here’s the short version: if your building was built before 1978, you probably need to comply. Yes, even if it’s been renovated. Yes, even if it “looks fine.”
You’re responsible if:
- Your building went up before 1960
- It was built between 1960 and 1978 and you know there’s lead paint
- It’s a 1- or 2-family home that’s rented, and not owner-occupied
- You’re renting out a condo or co-op unit, even in a luxury building
So if you’re a landlord, investor, or homeowner with a tenant, this law probably applies to you. It doesn’t matter if your kitchen has marble counters—if the bones are old, you need testing.
What You Actually Have to Do
Okay, here’s what the law requires—no fluff:
By August 9, 2025, you need to:
- Get XRF lead testing done in every unit and shared space
- Hire an EPA-certified inspector (not just anyone with a toolkit)
- Keep all your documents for 10 years
- Be ready to show those records if HPD asks
The testing is non-invasive. It won’t damage your walls. But you need the paperwork—and if it’s not on file, it didn’t happen as far as the city’s concerned.
If There’s a Child Under 6 in the Home
This part matters if a child under six lives in the unit—or moves in after January 1, 2025. The rules get stricter.
You’ll need to:
- Smooth the floors (no splinters or cracks)
- Seal or remove chewable surfaces
- Fix windows, doors, and anything else with friction or dust
If the child lived there before 2025, you’ve got until July 1, 2027. If they move in after that, you get three years from the move-in date.
What Happens at Tenant Turnover
New tenant? New rules.
Any time someone moves out, you’re expected to:
- Remediate lead hazards before leasing again
- Treat areas with signs of chewing (yes, teeth marks matter)
- Fix windows, sills, baseboards—any friction areas
And just like with testing, all the work must be done by certified professionals using lead-safe methods.
Annual Notices & Ongoing Checks
Even after the testing’s done, you’re not off the hook.
Every year, you need to:
- Send a lead paint notice to your tenants
- Do an annual inspection
- Keep records, especially if there’s ever been a violation or lead hazard
You’re building a trail of proof. That way, if anything goes wrong—or someone files a complaint—you’re covered.
What Happens If You Don’t Comply?
Here’s what you’re risking if you ignore this:
- A Class C violation from HPD (the most serious kind)
- Fines up to $1,500 per unit
- The city doing the work and sending you the bill
- A lawsuit from a tenant—especially if someone gets sick
So no, this isn’t the kind of thing you can “get to later.” Even one missed detail could delay a sale, tank a rental deal, or put you in legal trouble.
What Property Owners Should Do Now
You don’t need to panic—you just need a plan. Here’s your five-step checklist:
- Book your XRF testing now. Don’t wait for a rush next summer.
- Organize your records. Create a digital folder with test results, inspector info, and notices.
- Hire the right pros. Only use EPA-certified workers for remediation.
- Apply for an exemption if you qualify as lead-free or lead-safe.
- Stay in the loop. Bookmark the NYC HPD lead paint info page and check for updates.
What It Means for Sellers, Buyers & Brokers
For Sellers:
Lead compliance is the new “move-in ready.” If your unit isn’t tested or documented, it could hold up the entire deal.
For Buyers:
Ask to see the XRF test results. If it hasn’t been done, that’s a red flag. You don’t want surprise costs after closing.
For Brokers:
Make sure your listings are up to speed. This is now part of your client checklist. Educate sellers and protect buyers.
For Attorneys:
Review your contracts. Add clauses for lead testing, disclosure, and remediation. Waivers might not hold up anymore.
Takee’s Tip for Smart Sellers
Think of lead testing the same way you’d think about staging or fresh paint. It shows buyers the home is cared for, safe, and ready to go. That kind of peace of mind helps your listing stand out—and can make your sale smoother and faster. It’s not just about checking a box. It’s about showing you’re serious.
