Local Law 31 (2025): NYC Lead Paint Testing Deadline & What Property Owners Must Know

If You Own a Pre-1960 Building in NYC, 2025 Is a Big Year

As a property owner in New York City, especially if your building was built before 1960, you’ve got a hefty responsibility when it comes to lead-based paint compliance—and Local Law 31 is making that crystal clear in 2025.

Here’s the thing: lead poisoning, particularly in children, is serious business. NYC has been cracking down on compliance, and this year, the city is enforcing some non-negotiable deadlines. Most urgent? All apartments and common areas must be tested for lead paint by August 9, 2025.

Sound overwhelming? Don’t worry—we’re walking you through everything you need to know in plain, straight-to-the-point language.

Why Local Law 31 Matters

Let’s back up for a sec. Local Law 31 is part of a larger framework of NYC laws aimed at reducing childhood lead exposure. This law, passed in 2020, requires XRF testing of all apartments and common areas in buildings built before 1960 (or between 1960–1978 if lead-based paint is known or suspected).

And now? That long lead-up time is over. The law’s deadline—August 9, 2025—is just around the corner.

Failing to comply can result in:

Class “C” violations
Civil penalties of up to $1,500 per violation
Mandatory abatement orders from HPD

How to Get Your Building Tested (The Right Way)

You can’t just grab a test kit from Amazon and call it a day. NYC requires lead testing to be done using an XRF (X-ray fluorescence) device by a certified EPA lead inspector or risk assessor.

Here’s how to do it step-by-step:

Find a certified contractor
Go to www.epa.gov and search “lead certified contractors.” Only EPA-certified firms are authorized to test and perform remediation.
Test all units and common areas
Every apartment. Every hallway. Every stairwell. Get it all scanned with the XRF machine to determine where lead is present.
Get documentation
You must maintain written results of the testing. If a surface tests positive, it will read 0.5 mg/cm² or higher.
Store the records safely
These records must be kept for 10 years and produced on demand to HPD if they request them. No excuses.

What If Lead Is Found?

That depends on the condition and who’s living in the unit.

If there’s a child under 6 AND:

The paint is peeling or damaged —> Immediate remediation is required.
The paint is intact —> You don’t need to remove it, but you must monitor and maintain it properly.

No child under 6 in the unit?

Then you’re not legally required to abate or remove intact lead-based paint right away. However, if a child under six starts living there, the clock starts ticking.

Recordkeeping

Here’s a reminder most landlords miss:
You’re required to maintain all testing, remediation, and monitoring documentation for a full decade.

If HPD asks for records and you can’t produce them, it doesn’t matter if the work was done—you’ll still be slapped with a violation.

Also, beginning August 2025, if HPD issues a lead hazard or turnover violation, you must submit these XRF test results and other lead records immediately.

What If My Building Tests Negative?

Congrats! If all surfaces are below 0.5 mg/cm², your building qualifies for an exemption.

Here’s what you should do:

File for the lead exemption via HPD.
Keep the testing records on file.
Apply for exemptions for both apartments and common areas.

Once exempted, you’re no longer required to presume lead-based paint and won’t need to follow many of the annual monitoring rules—but you still need to maintain those test records.

What If a Child Under 6 Resides in My Building?

Big changes came with Local Law 123 of 2023:

Key obligations if a child under six lives in a unit with presumed lead-based paint:

Abate lead paint on all door and window friction surfaces
Remediate other hazards (like peeling paint or lead dust)
Make floors smooth and cleanable

Deadlines:

If the child lives in the unit on January 1, 2025, remediation must be done by July 2027
If a child moves in after Jan 1, 2025, you have 3 years from move-in date to remediate

Local Laws You Should Know (Besides LL31)

Let’s not forget, Local Law 31 isn’t acting alone. These newer laws are also influencing how HPD enforces compliance:

Local Law 122 (2023):
- Requires annual notice and investigation records
- Adds criteria for violation dismissal through proof of 10 years of recordkeeping or payment
Local Law 111 (2023):
- Requires common area XRF testing by August 2025
- HPD must also inspect paint conditions in common areas during complaint inspections
Local Law 127 (2023):
- Adds turnover compliance violations to the list of audit triggers

Don’t Miss These Deadlines

Requirement	Deadline
XRF Testing (all units & common areas)	August 9, 2025
Record submission upon violation	Starting August 2025
Child under 6 remediation (if in unit on Jan 1, 2025)	July 2027
Child under 6 remediation (moves in after Jan 1, 2025)	Within 3 years

Quick Reminders for Owners

Here’s your compliance checklist:

✅ Hire an EPA-certified XRF inspector
✅ Test all painted surfaces in units and common areas
✅ Keep test results for 10 years
✅ Monitor units with lead-based paint, especially if children under 6 reside there
✅ Apply for exemptions if everything tests negative
✅ Know and follow all remediation and recordkeeping rules
✅ Stay ahead of annual notice and turnover requirements

FAQs

What buildings does this apply to?
Any multiple dwelling built before 1960 or built between 1960–1978 with known lead-based paint.

How do I find a certified contractor?
Go to epa.gov and search “lead certified contractors.”

What if I already tested in the past?
You still need to ensure you have valid documentation and that all common areas are tested by August 2025.

Can I do testing myself?
No. Only EPA-certified inspectors using an XRF machine can conduct compliant tests.

Wrapping Up: Don’t Wait Until It’s Too Late

Local Law 31 isn’t going away—and it’s not getting any easier. NYC has made it clear that lead safety is a top priority, and enforcement is only getting stricter. If you’re a property owner, this is your chance to get compliant and avoid costly violations.

The clock is ticking, and August 9, 2025, will be here before you know it.

For more details, visit: www.nyc.gov/hpd and search “lead-based paint.”
To watch helpful walkthroughs and webinars, visit the HPD YouTube Channel and search “HPD Lead.”