NYC Local Law 123: What Landlords Need to Know Before the July 2027 Lead Paint Deadline

What Local Law 123 means for NYC property owners

Local Law 123 of 2023 amended New York City lead-paint requirements for certain apartments in older multiple dwellings. The law matters to landlords, building managers, property managers, and real estate professionals because it connects child-under-six occupancy with work that must be completed in the apartment. The issue is citywide, including Manhattan, Brooklyn, Queens, the Bronx, and Staten Island.

This article is about the Local Law 123 correction timeline and how existing testing information can help. It is not a substitute for an HPD determination, legal advice, or a contractor’s written scope of work. Building age, occupancy, turnover, prior work, notices, and the condition of the painted components all matter.

Which buildings and apartments are affected?

HPD’s current guidance addresses dwelling units in multiple dwellings erected before January 1, 1960. The child-under-six rule applies when a child under six resides in the unit. HPD describes a child-under-6 unit as one where a child under six routinely spends 10 or more hours per week.

The exact trigger is not simply “every pre-1960 apartment by the same date.” Local Law 123 also addresses apartment turnover and the date a child begins residing in an occupied unit. Owners should therefore classify each unit separately. Do not assume that a negative result in one apartment controls another apartment or a common area.

What is the July 1, 2027 deadline?

For a qualifying unit where a child under six resides as of January 1, 2025, HPD states that required lead-based paint work must be completed by July 1, 2027. If a child under six begins residing in an occupied unit after January 1, 2025, the applicable work is due within three years after the child begins residing there.

These are not separate opportunities to choose the latest date. HPD describes the required work as due at the earliest applicable trigger: apartment turnover, July 1, 2027 for the qualifying January 1, 2025 child-under-six situation, or within three years after a child under six begins residing in a unit after that date. A turnover can therefore require action before the July 2027 date.

HPD says the three-year clock is tied to when the owner learns that a child under six resides in the unit. That knowledge can come through the annual notice process, a lease or lease renewal, written tenant notice, or another form of actual knowledge. Document how and when the information was received. If a unit turns over, separate turnover requirements may apply regardless of the next tenant’s age.

What work can Local Law 123 require?

HPD describes abatement-level work in covered turnover and child-under-six units. The work can include remediation of lead-based paint hazards and the underlying defects causing deterioration. A painted surface should not be treated in isolation when moisture, leaks, damaged plaster, or another defect is causing the paint to fail.

Doors and door-frame friction surfaces

Lead-based paint on door and door-frame friction surfaces is a central issue. These are surfaces that rub as a door opens and closes, potentially generating lead dust. The required approach is not ordinary repainting. Depending on the component and condition, compliant work can involve removal of the lead-based paint, permanent covering with an appropriate system, or replacement. HPD notes that correction can result in replacement of the door or door frame.

Windows, channels, and slides

Window friction surfaces require careful component-level evaluation. Where applicable, the correction path can involve removal or permanent covering of lead-based paint, or installation of replacement channels or slides. A broad statement that every window must be replaced would be inaccurate. The report and the qualified work plan should identify which painted components actually require action.

Floors, window sills, and window wells

HPD requires applicable bare floors, windowsills, and window wells in the dwelling unit to be smooth and cleanable. These surfaces matter because dust can collect there. This is a condition requirement, not merely an XRF-testing requirement.

Lead hazards and underlying defects

Required work can include correcting peeling or deteriorated lead-based paint and fixing the underlying defect. Local Law 123 is not satisfied by documenting a positive XRF result and leaving a deteriorated surface unmanaged. The proper work depends on the condition, component, occupancy, and whether HPD or DOHMH issued a violation or order.

How Local Law 31 XRF results help

Local Law 31 required covered lead-paint investigations using XRF at the NYC action level of 0.5 mg/cm², with the main August 9, 2025 deadline now passed. For a broader explanation of the landlord testing scope, see the NYC landlord XRF testing guide. A usable XRF report should let an owner connect each result to a unit, room, component, substrate, and result classification.

Use the report to build a component map. Mark positive findings on doors, door frames, windows, channels or slides, sills, and other painted surfaces. Then compare that map with the current condition and the Local Law 123 work scope. If the report is incomplete, does not identify the component clearly, or leaves an important area untested, arrange targeted testing or professional review rather than guessing.

A negative XRF result can establish that the tested component did not meet the applicable lead-based-paint threshold at the tested location. It does not automatically establish that every layer, component, apartment, or defect is lead-free. It also does not determine whether a floor, sill, window well, or friction component is smooth, cleanable, intact, or otherwise compliant. Testing answers a paint-content question. It does not replace a condition inspection or required correction.

What to do when XRF results identify lead

1. Preserve the evidence. Keep the complete report, instrument and inspector information, floor plans or component schedules, and any inconclusive readings or paint-chip confirmations.
2. Separate identification from correction. A positive result tells you where lead-based paint was found. It does not by itself select the legal work method.
3. Evaluate the condition and trigger. Check for deterioration, friction, impact, chewable surfaces, moisture, turnover, child-under-six occupancy, and HPD or DOHMH orders.
4. Use an appropriately certified contractor. HPD distinguishes ordinary lead-safe renovation work from abatement and violation-related work. For city violation work, HPD guidance points owners to an EPA-certified lead abatement firm.
5. Plan independent post-work testing where applicable. Dust wipe clearance may be required by the work, order, or correction process. Keep the sampler, laboratory, and result documentation with the project file.

Safe work, clearance, and records

Paint-disturbing work in pre-1978 housing can trigger EPA Renovation, Repair and Painting requirements. NYC work performed under a violation or city order can require an EPA-certified lead abatement firm rather than an RRP firm. The certification path is determined by the work and the legal trigger, not by the owner’s preferred vendor.

After applicable lead correction or remediation, dust wipe testing may be part of the clearance process. Do not describe visual cleaning as clearance. Follow the applicable HPD, DOHMH, project, and contractor requirements, and retain the result.

HPD guidance calls for retaining applicable lead records for at least 10 years. Keep XRF reports, inspector and firm qualifications, annual notices and investigations, access attempts where relevant, turnover and child-under-six work records, safe-work or abatement documentation, and dust clearance results. Some HPD record-production requests also impose a response period, so an organized file matters.

How Local Laws 31, 111, 122, and 123 fit together

• Local Law 31: establishes the broad XRF investigation requirement and helps identify where lead-based paint is located.
• Local Law 111: expands or clarifies investigation scope, including applicable common areas and child-under-six timing.
• Local Law 122: addresses production of lead records in specified HPD processes. It is not a universal instruction to upload every XRF report immediately.
• Local Law 123: adds correction and abatement-level work requirements for qualifying turnover and child-under-six situations, including the July 1, 2027 date for certain units.

These laws interact with the broader Local Law 1 framework. An owner should not use the completion of one law’s testing requirement as proof that all other duties are complete.

Property-owner preparation checklist

How Rapid Lead Testing can help

Rapid Lead Testing helps NYC landlords, multifamily owners, property managers, building managers, and real estate professionals turn scattered testing records into a clearer testing plan. Services include XRF lead paint testing, NYC Local Law lead testing, lead dust wipe testing, post-remediation testing, lead violation testing and clearance assistance where applicable, and testing documentation for NYC property owners and managers.

We do not perform lead abatement or remediation. Our role is to test, document, and help you understand the testing side of the compliance process so you can coordinate with the appropriate remediation professional.

Frequently asked questions

What is Local Law 123 in NYC?

Local Law 123 is a New York City lead-paint law that adds required correction work for qualifying dwelling units in multiple dwellings erected before January 1, 1960. It focuses on units with a child under six and includes a July 1, 2027 deadline for certain units.

What is the July 1, 2027 NYC lead paint deadline?

July 1, 2027 is the deadline for required Local Law 123 work in a qualifying unit where a child under six resides as of January 1, 2025. If the child begins residing in the unit after that date, the applicable work is due within three years after the child begins residing there, based on when the owner learns of the child-under-six occupancy.

Who has to comply with Local Law 123?

The rule concerns qualifying dwelling units in multiple dwellings erected before January 1, 1960. The exact duty depends on the unit, occupancy, turnover status, child-under-six status, and applicable HPD requirements. Owners should confirm the building and unit facts rather than assume every NYC apartment has the same deadline.

Does Local Law 123 apply if my apartment already had XRF testing?

Yes, potentially. XRF testing identifies lead-based paint on tested components, but it does not by itself complete Local Law 123 correction work. Existing XRF results can help identify components that require attention and can show where further testing may not be necessary.

What are lead-painted friction surfaces?

Friction surfaces are painted components that rub during normal use. NYC guidance specifically addresses lead-based paint on doors and door frames. Window friction surfaces and window channels or slides may also matter depending on the component and applicable requirement.

Do lead-painted doors and windows have to be replaced?

Not automatically. Local Law 123 requires the applicable lead-based paint to be removed or permanently covered on covered friction surfaces, and HPD explains that compliant work can result in replacement of a door or frame. The proper method depends on the component, condition, test results, and qualified abatement plan.

What happens if my Local Law 31 XRF report found lead paint?

Organize the report by unit and component, identify positive and inconclusive results, and have the applicable hazards and defects evaluated. Then coordinate any required abatement or correction with a qualified contractor. Rapid Lead Testing can help review records and perform testing, but it does not perform abatement.

Do landlords need dust wipe testing after lead remediation?

Dust wipe testing may be required or appropriate after lead-related correction or remediation, depending on the work and the HPD, DOHMH, or project requirements. Use an independent qualified sampler or testing provider where required and retain the result with the work records.

Can a negative XRF result affect what work is required?

A negative result can establish that the tested component did not meet the applicable lead-based-paint action level at the tested location. It does not automatically prove that every component, layer, unit, or hazard is lead-free, and it does not replace inspection for defects or required correction work.

What records should an NYC landlord keep?

Keep XRF reports, inspector and firm qualifications, access records where relevant, annual notices and investigations, work documentation, safe-work or abatement records, dust clearance results, and turnover or child-under-six correction records. HPD says applicable lead records should generally be retained for at least 10 years.