The Complete NYC Commercial Compliance Guide (2026)

Local Law 11 (Facade Inspection Safety Program)

Local Law 11 of 1998, commonly called FISP (Facade Inspection Safety Program), requires exterior wall inspections on a 5-year cycle for all buildings greater than six stories. The current cycle is Cycle 10, which began January 1, 2025 and runs through February 21, 2030.

Who has to file?

Every building greater than six stories in NYC must have its exterior walls and appurtenances inspected by a Qualified Exterior Wall Inspector (QEWI), typically a licensed architect or professional engineer with specific experience.

Sub-cycle filing windows (Cycle 10)

• Sub-Cycle 10A — Block end digits 0, 1, 2 or 9. Due by February 21, 2027.
• Sub-Cycle 10B — Block end digits 3, 4, 5 or 6. Due by February 21, 2028.
• Sub-Cycle 10C — Block end digits 7 or 8. Due by February 21, 2029.

Report classifications

• Safe — No hazardous conditions, no unsafe conditions.
• Safe with a Repair and Maintenance Program (SWARMP) — Conditions that need attention but are not currently unsafe. Must be corrected before next cycle.
• Unsafe — Immediate hazard. Sidewalk shed required within specific days, repairs must follow.

Penalties

Late filing: $1,000 per month, retroactive to the filing deadline. Failure to correct Unsafe conditions: $1,000 per month per violation. Failure to correct SWARMP conditions from a prior cycle: $2,000.

Local Law 97 (Climate Mobilization / Emissions Limits)

Local Law 97 sets carbon emissions limits for buildings greater than 25,000 square feet. The first compliance period (2024-2029) requires emissions below Phase 1 thresholds. The second period (2030-2034) drops limits significantly. The third period (2035 onward) requires major retrofits for most existing buildings.

Who has to file?

Any building greater than 25,000 sq ft in NYC, plus certain combined-lot buildings. Some affordable housing, rent-regulated, and specific asset types are covered under alternative compliance pathways.

Key deadlines

• May 1, 2025 — First annual report for compliance year 2024 due.
• May 1 of each year thereafter — Annual emissions report for the prior calendar year.
• 2030 — Phase 2 limits apply. Most existing buildings require retrofit to comply.

Penalties

Exceeding your emissions limit carries a $268 per metric ton of CO2-equivalent over the cap, per year. A mid-sized office building over the limit by 500 tons could face $134,000 annually in penalties. Failure to file the annual report carries a separate $0.50 per sq ft per month penalty.

Local Law 84 (Benchmarking)

Local Law 84 requires annual energy and water benchmarking for buildings greater than 25,000 sq ft. Data is submitted through ENERGY STAR Portfolio Manager and published publicly by the city.

Deadline

May 1 of each year for the prior calendar year's data. Data must be verified by a Data Verifier (often a Professional Engineer or Registered Architect) every 5 years.

Penalties

$500 for the first violation quarter. $500 each additional quarter missed, up to $2,000 per year.

Local Law 87 (Energy Audits & Retrocommissioning)

Local Law 87 requires an ASHRAE Level II energy audit and retrocommissioning every 10 years for buildings greater than 50,000 sq ft. Reports are due by December 31 in the tax block year that matches the building's last digit.

Penalties

$3,000 for initial violation. $5,000 per year for continuing violations until EER is filed.

Local Law 152 (Gas Piping Inspection)

Local Law 152 requires periodic inspection of building gas piping systems by a Licensed Master Plumber (LMP) on a 4-year cycle, organized by community district.

Who has to file?

All buildings except Occupancy Group R-3 (1-2 family homes). Applies to commercial, multifamily, mixed-use, and industrial buildings with gas service.

Cycle dates (by Community District)

• Community Districts 1, 3 of all boroughs — Due by December 31, 2023 and every 4 years thereafter.
• Community Districts 2, 5, 7, 9 of all boroughs — Due December 31, 2024.
• Community Districts 4, 6, 8, 10 of all boroughs — Due December 31, 2025.
• Community Districts 11, 12, 14, 15, 16, 17 of all boroughs — Due December 31, 2026.

Penalties

$10,000 civil penalty for failure to file. $5,000 for late filing without extenuating circumstances.

Elevator Inspections

All passenger and freight elevators in NYC require annual Category 1 inspections (inspection + test) and five-year Category 5 tests. Reports are filed through DOB NOW.

Key requirements

• Category 1 — Annual inspection + periodic safety test. Must be filed within 14 days of test.
• Category 5 — Every 5 years, a more thorough full-load test.
• ASME A17.3 — Upgrade compliance for older elevators (pre-1981) may require door restrictors and other upgrades.

Penalties

$250 for late Category 1. $5,000 for operating without required inspection. Additional $250/month for failure to correct defects.

Boiler Registrations & Inspections

High-pressure boilers (>15 psi steam, >160 psi water) require annual inspections by a NYS-certified Boiler Inspector. Low-pressure boilers require a one-time internal inspection. Every active boiler must be registered with DOB.

Key requirements

• BR-1 (Annual Boiler Report) — Due annually based on anniversary of initial installation or last external inspection.
• BR-2 (Internal Inspection) — Low-pressure boilers, one-time after installation.
• NYCECC 2023 — Energy code compliance for replacements.

Penalties

$50 per month late BR-1 filing (up to $3,000). $1,500 for operating a high-pressure boiler without current inspection.

Backflow Prevention

DEP (NYC Department of Environmental Protection) requires annual testing of all backflow prevention devices (RPZ, double-check, etc.) by a NYS-certified Backflow Tester. Reports filed through DEP's online portal.

Penalties

Failure to test: water service can be shut off. Administrative fines from $500 to $2,500. Tenant displacement risk makes this a priority category.

Penalty Schedule Summary (typical commercial building)

How Filing Actually Works

Most NYC compliance filings now route through DOB NOW (the Department of Buildings online platform), ENERGY STAR Portfolio Manager (benchmarking), or the DEP portal (water/backflow). A few older categories still accept paper. Individual login credentials are tied to the licensed professional (QEWI, LMP, etc.), and property owner access happens through DOB NOW Property Profile.

Practical tip: set up a service-company-neutral document storage system. If you change inspectors or consultants mid-cycle, you need your prior reports. Don't let them sit in a vendor's portal.