Direct answer: what should I submit?

Follow the checklist in the HPD notice. HPD’s published recordkeeping guidance identifies four core parts of the XRF file: the testing results or report, the names of the people or contractors who performed the inspection, proof of the EPA certifications held by the inspector and firm, and the certified tester’s affidavit. If access to a covered unit was denied, include the required access-attempt documentation and no-access affidavit when applicable.

Do not assume the XRF report replaces every other item in a Record Production Order. HPD may also request annual notices, annual investigations, turnover records, safe-work-practice documentation, or dust-clearance results.

Why is HPD asking for my XRF report?

HPD asks for XRF records to determine whether an owner completed the applicable paint-testing requirement and can document it. The request may appear inside a Record Production Order or lead audit, in follow-up correspondence, or through a violation requiring proof of XRF testing.

HPD’s current audit page lists violation order 626 as an order to provide documents showing compliance with XRF testing. A broader Record Production Order requires lead-compliance records within 45 days. Your own notice controls the exact deadline and submission method.

Local Law 31’s one-time testing deadline has already passed for covered properties. HPD says covered owners had to use an independent EPA-certified lead inspector or risk assessor with an XRF device to test applicable dwelling units and common areas. The report is the evidence of what was actually tested; it is not merely a receipt for booking the inspection.

What needs to be in the XRF report package?

Build the response around HPD’s request, then organize the file so a reviewer can connect each document to the correct property and scope.

XRF results or report

The report should identify the property and document the painted components and areas actually tested.

Inspector identity

Include the name of the inspector or contractor who performed the lead-based paint inspection.

EPA qualifications

Include proof of qualification for both the EPA-certified inspector and the certified firm.

Testing affidavit

Include the applicable affidavit completed by the certified individual who performed the testing.

For a multi-unit building, add a simple cover index listing each apartment and common area, the matching report page or file, and whether any scope remains unresolved. An index helps HPD review the production, but it does not replace the underlying records.

Before submitting, compare the report with the building

  1. Confirm the address and building. Make sure the report belongs to the property named in the HPD request.
  2. Match every covered apartment. Compare the report’s unit list with the building’s actual residential units.
  3. Check common areas. In covered multiple dwellings, hallways, stairs, lobbies, and other applicable common areas may need their own documented testing.
  4. Verify credentials and affidavit. A report without the supporting inspector and firm records may leave the production incomplete.
  5. Read the action level in context. HPD says an owner with a qualifying 1.0 mg/cm² report generally need not retest solely to prove completed testing; a new lead-exemption application requires testing at 0.5 mg/cm².
  6. Follow the notice. Use the submission channel, file naming, property identifiers, and deadline stated by HPD.

What if I never did the inspection?

Do not manufacture, alter, or backdate a report. Preserve the HPD request, identify the response deadline, and arrange the missing inspection with an independent EPA-certified lead inspector or risk assessor as soon as possible. Send the inspector the HPD notice and building details so the scope is based on the actual request and property—not a guess.

If the deadline may arrive before the report is complete, contact the HPD unit listed on the notice or qualified counsel promptly about how to respond. Booking an appointment does not itself prove that the Local Law 31 inspection was completed.

Missing the report HPD requested?

Rapid Lead Testing can review the notice and existing records, define the documented XRF gap, and inspect the missing NYC units or common areas. Same-day report delivery may be available when scope, access, scheduling, and field conditions allow.

Request an XRF Inspection Review XRF Pricing

What if units or common areas are missing?

A partial report proves only the scope it documents. Create a gap list rather than treating the whole building as complete. Separate the units that were tested, units that were inaccessible, units that were omitted, and common areas that were outside the original scope.

For denied access, HPD says owners should retain written notices, records of contact attempts and the reasons access failed, plus the applicable no-access affidavit. HPD’s guidance also says owners should continue efforts to gain access. If an apartment was simply overlooked, arrange testing for that gap; do not edit the original report to imply it was included.

Reviewing the existing report first can prevent unnecessary duplicate testing. See the companion guide on reviewing an XRF report before submitting HPD lead records.

Does HPD accept XRF reports?

Yes. HPD expressly lists lead-based paint testing results or reports as records owners must keep and provide when requested. Acceptance still depends on whether the report matches the requested property and scope and whether the required inspector, firm, and affidavit records are included.

An older report is not automatically unusable. HPD’s current FAQ says an owner who has a qualifying report from testing at 1.0 mg/cm² is not required to retest at 0.5 mg/cm² solely to be compliant with the completed-testing requirement. The distinction matters when the owner is applying for a new lead exemption: HPD requires 0.5 mg/cm² testing for that separate process.

Do I send every XRF report to HPD automatically?

HPD’s public guidance says to keep XRF records for at least 10 years and provide them when HPD requests them. That retention-and-production rule is not the same as a universal requirement to upload every report immediately after every inspection.

If you received a notice, follow that notice. If you completed testing but have not received a request, preserve the report, credentials, affidavits, access records, and any related correspondence in the property’s lead file. Transfer the records to the new owner if the property is sold.

Frequently asked questions

Why is HPD asking for my XRF report?

HPD may request it to verify the one-time XRF investigation or as part of an audit, Record Production Order, or XRF-documentation violation. HPD says owners must retain the report and provide it when requested.

What needs to be in the XRF report package I submit to HPD?

HPD identifies the report or results, inspector or contractor names, proof of the EPA-certified inspector and firm qualifications, and the certified tester’s affidavit. Include any additional records specifically listed in your notice.

What if I never completed the XRF inspection?

Do not create or backdate documentation. Review the notice and deadline, preserve it, and arrange testing with an independent EPA-certified lead inspector or risk assessor. Contact the HPD unit listed on the notice or qualified counsel if timing or scope is unclear.

What if apartments or common areas are missing from my XRF report?

Treat the report as proof only for the areas it covers. List the gap, retain required access-attempt records for inaccessible units, and arrange testing for omitted covered units or common areas.

Does HPD accept XRF reports?

Yes. HPD lists XRF testing results or reports as compliance records. The report must fit the property, required scope, inspector qualifications, and purpose of the request.

Do I have to send every XRF report to HPD automatically?

HPD tells owners to keep testing records for at least 10 years and provide them when requested. That is different from a universal immediate-filing rule.

For more detail, review Rapid Lead Testing’s Local Law 31 XRF service, the 2026 landlord XRF requirements guide, and the full HPD Record Production Order checklist. The Rapid Lead Testing NYC lead resource guide also maps the site’s landlord, tenant, testing, and property-record tools by question.

Primary sources checked September 10, 2026: NYC HPD, Required Audit Compliance and Record-Keeping; and NYC HPD, Paint Testing Requirement and Exemptions. This is compliance information, not legal advice. The property, notice, and HPD process determine the exact response.