RAND Building News & Insights, January 2025
Staying on top of NYC’s building compliance deadlines is more important than ever. This year is a critical one for compliance, with major Local Law 97 and 88 deadlines driving significant changes in energy efficiency and sustainability. The City has also introduced new penalties for parapet inspections and parking structure observation checklist inspections, along with increased fines for parking structure inspections (PIPS) and other areas. For those needing more time to file their Local Law 97 emissions report, extension requests may be available under certain conditions—details can be found in our compliance calendar below.
To help you stay organized and avoid costly violations, we’re offering a downloadable compliance calendar checklist and a Google Calendar you can subscribe to so you’ll never miss an important deadline.
Key Compliance Dates for 2025
Here are some of the most critical deadlines property owners and managers need to track this year.
February 21, 2025
FISP Cycle 10A Filing Window Opens
Buildings with block numbers ending in 4, 5, 6, and 9 must complete and file their FISP reports by February 21, 2027. Late filings incur penalties of $1,000/month, and failure to file results in fines of $5,000/year. FISP inspections often uncover facade issues that require repairs. Scheduling early provides more time to assess conditions, budget for necessary work, and avoid costly emergency repair. Acting now helps secure prioritized inspection scheduling and prevents last-minute delays before the deadline rush.
May 1, 2025
Carbon Emissions Reporting – Local Law 97
Starting in 2025, owners of buildings 25,000 SF or larger must report compliance with annual carbon emissions limits starting in 2025. Penalties include $268 per metric ton of emissions above the limit and $0.50 per square foot per month for late reporting. False statements carry fines of $500,000 and/or imprisonment.
Owners unable to file emissions reports by the May 1, 2025 deadline may apply for an extension under specific conditions:
- All LL97-covered buildings: If the Registered Design Professional (RDP) could not complete the report on time. Owners must provide a contract showing the professional was hired by February 1, 2025, and a signed affidavit confirming the delay.
- Buildings disputing covered status under Article 320 or 321: Owners must submit a signed attestation and all related correspondence.
Requests must be filed 30 days before to 60 days after the deadline with supporting documentation. Approved extensions require the final report to be submitted within 120 days of the original deadline or final determination. For full details, refer to the DOB’s official rule.
Lighting Upgrades & Sub-Metering – Local Law 88
Buildings 25,000 SF or larger must have lighting upgrades and tenant sub-metering completed by this date. Non-compliance results in fines of $1,500 annually for missing reports and $500 per tenant space for non-compliant sub-meters.
Benchmarking – Local Law 84
Annual energy and water usage reporting is required for buildings 25,000 SF or larger. Missing the May 1 deadline results in fines of $500 per quarter, up to $2,000 annually.
October 1, 2025
New York State Parking Garage Inspection Compliance
Parking garages in New York State must undergo periodic inspections and file certifications every three years, as required by the NYS Uniform Code. Deadlines are based on the date of the initial inspection, with the next cycle of certifications beginning October 1, 2025. Failure to comply may result in fines or enforcement actions. Note: Parking garages in New York City are governed by the NYC Periodic Inspection of Parking Structures (PIPS) Program, which operates under its own set of requirements and deadlines distinct from the state regulations.
October 31, 2025
Energy Efficiency Grades Must Be Posted
At buildings over 25,000 SF, a Building Energy Efficiency Rating label must be posted near each public entrance by October 31, per Local Law 84. Labels are available in the DOB NOW Public Portal starting October 1. Non-compliance results in a $1,250 annual fine.
November 1, 2025
Cooling Tower Compliance
Under New York City regulations, property owners and managers must comply with annual certification requirements for cooling towers, evaporative condensers, and fluid coolers. The requirements include: registering cooling towers with the NYC Department of Buildings; performing regular inspections, maintenance, and water testing; and submitting an Annual Certification of Compliance through the DOB’s Cooling Tower Portal.
December 31, 2025
Annual Parapet Inspections
Annual parapet observation reports must be completed annually by December 31 and kept on file. The penalty for failing to provide the required annual parapet observation report upon request is a minimum of $1,250, with a maximum penalty of $10,000.
PIPS Parking Structure Inspection Deadline for Manhattan & Brooklyn (Sub-Cycle 1B)
Parking structures in Manhattan Community Districts 8 through 12, in addition to all Brooklyn districts, must have periodic inspections completed by this deadline. Non-compliance can result in fines of up to $17,000 per year.
PIPS Parking Structure Annual Checklist Inspection Deadline
Owners of all parking structures must submit annual checklist inspections by December 31, based on the initial condition assessment. Missing this requirement carries annual fines of up to $10,000.
Gas Piping Inspections – Local Law 152
Buildings in Community Districts 2, 5, 7, 13, and 18 across all boroughs must submit gas piping inspection certifications by this date. Non-compliance results in annual fines of up to $10,000.
Energy Audits & Retro-Commissioning – Local Law 87
Buildings with block numbers ending in 5 must submit their Energy Efficiency Report (EER). Penalties for non-compliance include fines of $3,000 in the first year and $5,000 annually thereafter.
Retaining Wall Inspections – Local Law 37
Owners of buildings in Manhattan with retaining walls taller than 10 feet and facing a public right-of-way must complete periodic inspections. Non-compliance carries fines of up to $1,000 per year.
Annual Boiler Inspections
High- and low-pressure boilers in NYC must undergo annual inspections, with results filed by December 31. For details, visit the NYC Boiler Compliance Page or check out our Boiler Maintenance Checklist to minimize breakdowns.
Annual Elevator Inspection Deadline
NYC property owners must comply with annual elevator inspection and testing requirements. Failure to inspect or file reports can result in fines of up to $1,000 per elevator per violation. Learn more at the NYC Elevator Safety Requirements.
Need help meeting these deadlines?
Contact our team at 212-675-8844 or info@nullrandpc.com to make sure your building is on track for full compliance.
Access Your Compliance Calendar Tools:
- Downloadable Checklist: Get your 2025 NYC Compliance Checklist
- Google Calendar: Subscribe to our NYC Compliance Calendar
About RAND
Founded in 1987, RAND Engineering & Architecture, DPC is a New York City firm that designs and administers programs for repair, upgrade, restoration, and adaptive re-use of residential, commercial, institutional, and retail properties. Our expertise includes exterior envelope repair, with a particular focus on FISP; parapet inspections and repair programs; window and door replacement; heating, plumbing, and electrical upgrades; garage inspections and repair programs; architectural design and ADA compliance; feasibility studies and plan reviews; structural engineering; forensic surveys; benchmarking, energy audits, and retro-commissioning; green roofs; and historic restoration. RAND also has a Building Design Group, an Industrial Rope Access Group, a Drone Services Group, an Infrared Survey Group, a 3D Laser Scanning Group, and a Code & Zoning Compliance Team, and is also a Special Inspections Agency. Please visit randpc.com for more information.
