CRITICAL DEADLINE

January 1-15, 2026: Annual lead paint notices must be delivered to ALL tenants in pre-1960 buildings

Tenant response deadline: February 15, 2026

What Are Annual Lead Paint Notices?

Under NYC Local Law 1, landlords of buildings constructed before 1960 must send annual lead paint notices to all tenants every year between January 1 and January 15. This notice informs tenants about lead paint hazards and asks them to report whether any child under the age of 6 resides or regularly spends 10+ hours per week in the unit.

This isn't a suggestion—it's a legal requirement with severe penalties for non-compliance. The notice must be delivered annually, even if you sent one last year to the same tenants.

Related Services

We provide expert Local Law 1 compliance services:

Turnover XRF Inspections Violation Clearance

Who Must Send Annual Notices?

Buildings Required to Send Notices:

  • All buildings constructed before 1960 (presumed to contain lead paint)
  • Buildings constructed 1960-1978 where lead paint is known or suspected
  • All dwelling units within these buildings, including:
    • Occupied rental units
    • Vacant units between tenants
    • Owner-occupied units in mixed-use buildings

Exemptions:

  • Buildings with valid lead-free certifications from XRF testing
  • Owner-occupied single-family homes with no tenants
  • Buildings constructed after 1978 (unless lead paint is present)

Important Note

Even if you believe your building is lead-free, unless you have official XRF testing certification proving it, you are legally required to send annual notices. "We painted over it" or "It looks fine" is not sufficient.

Critical Deadlines and Timeline

Jan 1-15

Landlord Sends Annual Notice

Deliver lead paint notice to all tenants using approved methods (hand delivery, certified mail, or posted/mailed combination)

Feb 15

Tenant Response Deadline

Tenants must return the signed acknowledgment form by February 15. Landlords must follow up with non-responsive tenants.

Within 10 days

Inspection Required (If Child Present)

If a tenant reports a child under 6 residing in the unit, landlord must conduct lead paint inspection within 10 days

10 years

Record Retention

Maintain copies of all notices, delivery proof, and tenant responses for 10 years. HPD can audit at any time.

What Must the Notice Include?

The annual notice must include specific information mandated by NYC law:

Required Notice Components

  • Building information: Address and year of construction
  • Lead paint disclosure: Statement that the building was built before 1960 and may contain lead paint
  • Child occupancy question: Ask if any child under 6 lives in or regularly visits (10+ hours/week) the unit
  • Health risks: Information about lead paint hazards and childhood lead poisoning
  • Tenant rights: Information about annual inspection rights if child under 6 is present
  • Response deadline: February 15 deadline for tenant to return form
  • Landlord contact info: Name, address, and phone number
  • HPD contact info: Phone number for tenant complaints (311)

Sample Annual Lead Paint Notice

SAMPLE NOTICE - Annual Lead Paint Disclosure and Child Occupancy Form

IMPORTANT NOTICE TO TENANTS
ANNUAL LEAD-BASED PAINT NOTICE
Required by NYC Local Law 1 of 2004

Date: January 10, 2026
To: [Tenant Name]
Unit: [Unit Number]
Building: [Building Address]
Year Built: 1955

NOTICE OF POSSIBLE LEAD-BASED PAINT HAZARD

This building was constructed before 1960 and may contain lead-based paint. Lead from paint, paint chips, and dust can pose health hazards if not managed properly. Lead exposure is especially harmful to young children and pregnant women.

ANNUAL CHILD OCCUPANCY DISCLOSURE REQUIRED

New York City law requires you to inform your landlord whether any child under 6 years of age resides in your apartment or regularly spends 10 or more hours per week there. Please complete the information below and return this form to your landlord by February 15, 2026.

TENANT RESPONSE (Check one):

☐ YES - A child under 6 years old DOES reside in or regularly visit this apartment
Child's Name: _______________________
Child's Date of Birth: _______________________

☐ NO - No child under 6 years old resides in or regularly visits this apartment

Tenant Signature: _______________________ Date: _________
Print Name: _______________________

YOUR RIGHTS:

  • If a child under 6 lives in or regularly visits your apartment, your landlord must conduct an annual lead paint inspection.
  • If lead paint hazards are found, your landlord must correct them using safe work practices.
  • You have the right to request lead testing at any time.
  • For questions or complaints, call 311 or visit nyc.gov/hpd

LANDLORD INFORMATION:
Name: [Your Name or Management Company]
Address: [Your Address]
Phone: [Your Phone Number]
Email: [Your Email]

Please return this completed form by February 15, 2026 to:
[Return Address or drop-off location]

Official Notice Templates

HPD provides official notice templates in multiple languages at:
nyc.gov/hpd → Search "Annual Notice Lead Paint"

Templates available in: English, Spanish, Chinese, Russian, Korean, Bengali, Arabic, Haitian Creole, Polish, and Urdu.

How to Deliver the Notice Legally

Simply emailing or texting the notice is not sufficient. NYC law requires one of these approved delivery methods:

Method 1: Hand Delivery (Most Reliable)

  • Deliver the notice directly to the tenant
  • Obtain the tenant's signature acknowledging receipt
  • Keep signed copy for your records
  • Advantage: Immediate proof of delivery

Method 2: Certified Mail

  • Send via USPS Certified Mail with return receipt requested
  • Keep the certified mail receipt (green card) as proof
  • Advantage: Postal service confirms delivery
  • Disadvantage: Tenants may not sign for certified mail

Method 3: Post and Mail (HPD-Approved Combination)

  • Tape the notice to the apartment door
  • Also send a copy via regular first-class mail
  • Take a photo of the posted notice with date/time stamp
  • Keep mailing receipt
  • Advantage: Accepted method even if tenant doesn't respond

Insufficient Delivery Methods

These methods do NOT meet legal requirements:

  • Email only
  • Text message
  • Sliding under the door
  • Regular mail only (without posting)
  • Verbal notification

HPD will not accept these as proof of delivery if you receive a violation.

What If Tenants Don't Respond?

It's common for tenants to ignore the notice. Here's what to do:

  1. Document your delivery attempt: Keep proof you sent the notice (certified mail receipt, photo of posted notice, etc.)
  2. Send a follow-up notice: Around February 1, send a reminder that the response is due February 15
  3. Assume no child present if no response: If tenant doesn't respond by February 15, you can assume no child under 6 is present
  4. Keep records: Document the non-response. This protects you during HPD audits.

Legal Protection

If you properly delivered the notice and the tenant didn't respond, you are generally protected from violations—as long as you can prove delivery. This is why documentation is critical.

What Happens If a Child Under 6 is Reported?

If a tenant reports that a child under 6 lives in or regularly visits the unit, you must take immediate action:

Required Actions (Within 10 Days):

  1. Conduct visual inspection for peeling paint, chipping, or deteriorating surfaces
  2. Hire EPA-certified inspector for XRF testing if deteriorating paint is found
  3. Remediate any hazards using EPA safe work practices
  4. Conduct clearance testing (dust wipe sampling) after repairs
  5. Provide tenant with results within required timeframe

Annual Inspection Requirement:

Once a child under 6 is identified in a unit, you must conduct an annual lead paint inspection every year until the child turns 6 or moves out. This includes:

  • Visual inspection of all painted surfaces
  • XRF testing of any deteriorating areas
  • Remediation of any lead hazards found
  • Documentation retained for 10 years

Penalties for Non-Compliance

Violation Penalties

Missing Annual Notice: $1,000 - $5,000 per violation

Failure to Inspect After Child Reported: $250/day Class C violation (up to $10,000)

Missing Documentation: $1,000 - $5,000 during HPD audits

Total Potential Cost: A building with 10 units could face $10,000-$50,000 in fines for missing annual notices alone.

Real Example:

A Brooklyn landlord with a 12-unit pre-1960 building failed to send annual notices in 2024. During an HPD inspection triggered by a tenant complaint, the violation was discovered.

  • 12 units × $3,000 average penalty = $36,000 in fines
  • Plus: Legal fees to dispute ($5,000+)
  • Plus: Emergency XRF testing and remediation ($8,000+)
  • Total cost: ~$50,000

Compare this to the cost of printing and mailing 12 notices: ~$50-100.

Annual Notice Checklist for Landlords

Complete Annual Notice Checklist

  • ☐ December: Prepare notice forms (download from HPD or use previous year's template)
  • ☐ January 1-5: Print notices for all units (include multiple languages if needed)
  • ☐ January 5-10: Deliver notices using approved method (hand delivery, certified mail, or post + mail)
  • ☐ January 10: Document delivery (photos, receipts, signatures)
  • ☐ January 15: Deadline—all notices must be delivered by this date
  • ☐ February 1: Send reminder to non-responsive tenants
  • ☐ February 15: Tenant response deadline
  • ☐ February 20-25: Schedule inspections for units with children under 6
  • ☐ File and retain: Keep all notices, delivery proof, and responses for 10 years

Best Practices for Compliance

1. Create a Master Tenant List

Maintain an updated spreadsheet with:

  • Tenant names
  • Unit numbers
  • Delivery method used
  • Delivery date and time
  • Response received (Yes/No)
  • Child present (Yes/No)
  • Inspection date (if required)

2. Use a Delivery Tracking System

For larger buildings, consider:

  • Hiring a process server for hand delivery and documentation
  • Using property management software with notice tracking
  • Creating a photo log of posted notices with timestamps

3. Translate Notices When Needed

NYC has significant non-English speaking populations. Provide translated notices to improve response rates and demonstrate good faith compliance.

4. Set Up Annual Reminders

Add recurring calendar reminders:

  • December 15: Prepare annual notices
  • January 1: Begin delivery process
  • January 15: Delivery deadline
  • February 15: Tenant response deadline

Common Mistakes to Avoid

Top Compliance Mistakes

  • Assuming old tenants don't need new notices: Even if the same tenant has been there for years, you must send a new notice every January
  • Only notifying units with children: ALL units must receive notices, regardless of whether children live there
  • Using email only: Email is not a legally acceptable delivery method
  • Forgetting vacant units: Vacant units must also receive notices (post on door)
  • Not keeping proof of delivery: Without documentation, you cannot prove compliance during audits
  • Ignoring child reports: If a tenant reports a child, you must act within 10 days

Frequently Asked Questions

Do I need to send notices to month-to-month tenants?

Yes. All tenants, regardless of lease type, must receive annual notices.

What if a tenant moves in after January 15?

You must provide the lead paint disclosure during lease signing (separate from annual notice). They will receive the annual notice the following January.

Can I include the notice with rent bills?

Yes, but it must still be delivered using an approved method (hand delivery, certified mail, or post + mail). Simply including it in a rent statement sent by regular mail is insufficient.

What if my building is lead-free?

If you have official XRF testing certification proving the entire building is lead-free, you are exempt from annual notices. Keep these certifications on file for HPD audits.

Do I need to send notices in other languages?

While not legally required, it's strongly recommended if your tenants speak other languages. HPD provides templates in 10 languages to help with compliance.

How Rapid Lead Testing Can Help

We assist NYC landlords with full annual notice compliance:

  • XRF Testing: Obtain lead-free certification to eliminate annual notice requirements forever
  • Child-Occupied Unit Inspections: EPA-certified inspections within required timeframes
  • Clearance Testing: Post-remediation dust wipe sampling for HPD compliance
  • Documentation Support: Reports formatted for HPD submission
  • Compliance Consulting: Guidance on notice requirements and inspection obligations

Pro Tip: Eliminate Annual Notices Forever

Consider investing in comprehensive XRF testing to obtain a lead-free certificate. While it costs more upfront ($249-$399 per unit), it:

  • Eliminates annual notice requirements permanently
  • Increases property value
  • Reduces ongoing compliance costs
  • Provides marketing advantage ("Certified Lead-Free")
  • Protects against future regulation changes

For a 10-unit building, XRF testing (~$3,000 one-time) is cheaper than 5 years of annual notice compliance efforts and potential violations.

Conclusion: Don't Miss the January Deadline

The annual lead paint notice requirement is one of the most commonly violated NYC landlord obligations—not because it's difficult, but because landlords forget or underestimate the consequences.

With penalties ranging from $1,000-$5,000 per unit and the January 15 deadline approaching quickly, now is the time to prepare your notices, update your tenant list, and establish a delivery tracking system.

Action Required

Prepare and deliver your annual lead paint notices by January 15, 2026

Tenant response deadline: February 15, 2026

Whether you need XRF testing to eliminate annual notices, emergency inspections for child-occupied units, or compliance consulting, Rapid Lead Testing is here to help.

Need Help with Compliance?

Contact us today for XRF testing, child-occupied unit inspections, or compliance guidance:

Phone: 917-727-6541
Email: rapidleadtesting@gmail.com

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