Local Law 31 NYC: 2025 Lead Inspection Guide for Landlords

 

A Queens landlord recently shared a story at a housing forum: after years of renting out a six-unit pre-war building without issue, he suddenly received notice that he had just six months to complete certified lead paint inspections under Local Law 31. The deadline? August 9, 2025. He faced thousands of dollars in potential fines if he missed it — and even worse, the possibility of stop-work orders if he tried to renovate.

He’s not alone. Thousands of New York City landlords are now facing the same reality. Local Law 31 (LL31) isn’t just another item on the compliance checklist — it’s the city’s most aggressive step yet in preventing childhood lead poisoning. According to the NYC Department of Health, more than 6,000 children under age six were identified with elevated blood lead levels between 2018 and 2022. That urgency is why the city set hard deadlines and strict penalties.

This guide explains exactly what landlords must do in 2025 to comply with Local Law 31 — who it applies to, the deadlines, the certification process, and how to handle it quickly without risking fines or tenant trust.

 

What Is Local Law 31 in NYC?

Q: What is Local Law 31?
Local Law 31 (LL31) of 2020 is New York City legislation requiring certified lead-based paint inspections in nearly all older residential buildings. The expanded enforcement begins August 9, 2025, and requires every covered building to complete XRF (X-ray fluorescence) testing of painted surfaces in both dwelling units and common areas.

Unlike earlier laws that targeted only “high-risk” apartments or those with children under six, LL31 requires city-wide testing across pre-1960 housing and certain properties up to 1978. The testing must be performed by EPA-certified inspectors or risk assessors — landlords cannot self-certify, and visual inspections no longer satisfy requirements.

Q: How does LL31 differ from earlier rules like Local Law 1 of 2004?

  • Broader coverage: all pre-1960 units, not just apartments with children.

  • Mandatory XRF technology: standardizes testing across all buildings.

  • Lower thresholds: any paint at or above 0.5 mg/cm² is considered lead-positive.

  • Stronger penalties: fines up to $1,500 per violation and possible HPD abatement orders.
     

NYC HPD official guidance confirms these requirements and provides a FAQ for property owners.

 

Who Needs Local Law 31 Lead Inspections in 2025?

Q: Does this apply to every landlord?
Nearly every NYC property owner of older housing is included.

  • Pre-1960 buildings: All residential properties must be inspected, regardless of renovations or whether children live there.

  • 1960–1978 buildings: If there is known or suspected lead paint, inspections are required.

  • Small landlords (1–2 family rentals): If not owner-occupied, they are also covered — a major change from past rules that often exempted them.

  • Large landlords and property managers: Every single unit plus common hallways, lobbies, and stairwells must be tested.
     

Q: Are there exemptions?
Yes, but only if a certified XRF inspection after 2021 proves no lead-based paint above the action level. Even then, exemptions must be filed with HPD and only apply to the units tested.

Q: What about tenant factors?
If a child under six moves into a unit after January 1, 2025, landlords must complete lead testing within one year, even if the building had been previously certified.

For clarity: tenant complaints are not the trigger anymore — the law itself is.

 

Local Law 31 Compliance Requirements and Deadlines

The primary deadline:

  • August 9, 2025 – all applicable buildings must complete XRF testing of every dwelling unit and common area.
     

Additional triggers:

  • Child under six move-in or lease renewal → inspection within one year.

  • Remediation follow-up → clearance testing and documentation required.
     

Required Documentation

Landlords must provide tenants with:

  • Certified test results from EPA-licensed inspectors.

  • Lead-safe certifications or proof of remediation.

  • Annual notices of lead hazard status.
     

All documents must be retained for at least 10 years and made available upon request.

Penalties for Missing the Deadline

  • Class “C” HPD violations, with fines up to $1,500 per violation.

  • Mandatory abatement orders (HPD can order removal at landlord’s expense).

  • Increased scrutiny during sales, refinancing, or inspections.

  • Repeat violations can escalate into lawsuits and higher penalties.
     

 

 

How to Get a Local Law 31 Lead-Safe Certification Fast

Landlords often ask, “What happens after I call an inspector?” The process is clearer than most expect.

Step-by-Step Process

  1. Determine if your property qualifies
    If built before 1960, or between 1960–1978 with lead paint, assume compliance is required.
     

  2. Hire an EPA-certified inspector
    Inspectors must be independent third-parties. Confirm certifications:

    • EPA Lead Inspector or Risk Assessor license

    • NYS Department of Labor certification

    • ELAP accreditation for lab work
       

  3. XRF testing of all surfaces
    Walls, doors, trim, windows, stair rails, and baseboards are scanned. Testing measures lead concentration in mg/cm².
     

  4. Receive results
    Average turnaround: 48–72 hours. Providers like UNYSE offer 24-hour turnaround, faster than the industry standard.
     

  5. Remediate if hazards found
    Use HPD-approved abatement methods. Clearance testing required afterward.
     

  6. File results and provide to tenants
    Documentation must be submitted to HPD and shared with occupants.
     

  7. Retain all records
    Keep files for 10 years in case of inspection or tenant request.
     

 

Comparison: Lead Inspection Cost vs. Penalties

Item

Cost Estimate

Impact

XRF Inspection (per unit)

$300–$600

Certifies compliance

Full Building (10 units)

$3,000–$6,000

Usually discounted

Missed Deadline Fine

$1,500 per violation

Can exceed cost of inspection in one month

Stop-Work Order Delay

$10,000+

Lost rent, legal fees, abatement costs

This table shows why waiting is not worth it. One inspection pays for itself by preventing a single violation.

 

Case Study: UNYSE’s Compliance Track Record

In Buffalo, UNYSE partnered with HUD on lead hazard control projects covering hundreds of rental units. Working under strict federal oversight, UNYSE completed inspections, remediation, and clearance within tight turnaround deadlines, enabling property owners to continue renting without interruption.

That same expertise applies in NYC. The 30+ years of certified experience and government recognition reassure landlords that LL31 compliance can be completed quickly and without risk.

 

Common Landlord Misconceptions

  • “No children live in my building, so I’m exempt.” False. LL31 requires testing regardless.

  • “A visual check is enough.” False. Only XRF testing by certified inspectors is valid.

  • “I renovated, so I don’t need to test.” False. Unless you have certified documentation after 2021, inspections are still required.

  • “I’ll wait until tenants complain.” Dangerous. Penalties are automatic once deadlines pass.
     

FAQs

Q: How soon can I get results?
Within 24–72 hours, depending on provider.

Q: Will tenants need to vacate?
No. XRF testing is non-destructive and takes minutes per unit.

Q: Is it disruptive?
Minimal. Inspectors scan surfaces quickly with handheld devices.

Q: What if lead is detected?
You must remediate using approved methods, then schedule clearance testing.

Q: Can I combine inspections?
Yes. Many landlords bundle lead, asbestos, and mold testing to save time.

 

Local Law 31 is not optional, and the August 9, 2025 deadline is approaching faster than many landlords realize. The good news? Compliance is straightforward when handled early, and far less costly than risking violations.

By scheduling inspections now, property owners protect tenants, preserve property value, and eliminate the risk of $10,000+ penalties or halted renovations.

UNYSE delivers certified inspections with 24-hour turnaround, backed by 30 years of compliance expertise across New York State. That means landlords can go from confusion to compliance in a single day.

Schedule your certified inspection today with UNYSE and secure your Local Law 31 lead-safe certification before the 2025 deadline.