Many property owners have already completed the required Local Law 31 XRF testing for lead-based paint hazards — but NYC’s Local Law 123 adds an important new compliance requirement that owners should not overlook.

Under Local Law 123, landlords of pre-1960 residential buildings may now be required to perform lead abatement work in occupied apartments where a child under six resides. Unlike prior rules that focused primarily on testing and turnover work, this law requires permanent remediation of certain lead-painted surfaces even while tenants remain in place.

The new requirements most commonly impact:

• Apartment entry doors
• Door frames and jamb
• Window and friction surfaces
• Other components identified as lead hazards

A key change under the law is that remediation must meet turnover-level standards, even if the tenant is not vacating the apartment.

Important Deadlines

Property owners should be aware of the following compliance timelines:

• If a child under six resided in the apartment as of January 1, 2025, required abatement work must be completed by July 2027.
• If a child under six moves into the apartment after January 1, 2025, owners generally have three years from the move-in date to complete the required work.

What Owners Should Do Now

• Owners and managers should begin reviewing:
• Existing Local Law 31 XRF reports
• Apartments occupied by young children
• Potential lead hazard conditions requiring remediation
• Budgeting and scheduling for future abatement work

As NYC continues expanding lead safety enforcement, proactive planning and documentation will be critical to avoiding violations and protecting tenant safety.