RAND Building News & Insights, September 2025 Update
As we enter the final stretch of 2025, several major compliance deadlines are coming up — with some key updates since we first shared our calendar earlier this year. New York City has adjusted reporting timelines for Local Laws 97, 88, and 84, offering extensions for buildings that applied for an LL97 deadline extension by August 29.
Keep in mind that some deadlines may still shift as new guidance is released. To stay current, we recommend downloading our updated 2025 Compliance Calendar Checklist and subscribing to our Compliance Calendar 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.
June 30, 2025
Carbon Emissions Reporting – Local Law 97
Owners of buildings 25,000 SF or larger were required to report compliance with 2024 carbon emissions limits by June 30, 2025. Buildings that submitted an extension request by the August 29 deadline now have until December 31, 2025 to file. Penalties for non-compliance include $268 per metric ton of emissions above the limit and $0.50 per square foot per month for late reporting. Knowingly filing false information may result in fines up to $500,000 and/or imprisonment.
Lighting Upgrades & Sub-Metering – Local Law 88
The deadline to report 2024 carbon emissions for buildings 25,000 SF or larger was June 30, 2025. Buildings that applied for an extension by the August 29, 2025 cutoff now have until December 31, 2025 to submit their emissions report.
Buildings that did not file or receive an extension may now be subject to enforcement. Penalties include $268 per metric ton of emissions above the limit and $0.50 per square foot per month for late reporting. Knowingly submitting false information can result in fines of up to $500,000 and/or imprisonment.
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. Note: For buildings that applied for and received an LL97 extension, the LL84 extended deadline is August 29, 2025.
August 9, 2025
Lead Paint Inspections – Local Law 55
Owners of multiple dwellings built before 1960 (or between 1960–1978 if the owner knows lead paint is present) must conduct annual inspections for lead-based paint hazards in units where children under 6 reside. Results must be documented, and remediation is required where hazards are found. Non-compliance carries fines and potential litigation.
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
Local Law 97 Report Extended Deadline (if extension filed)
Final deadline to file emissions report for buildings with approved LL97 extension.
Local Law 88 Report Extended Deadline (if LL97 extension filed)
This extension allows more time to file required lighting and sub-metering reports, but all LL88 measures must still be implemented to avoid penalties.
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
For parking structures that have already filed an Initial Observation Report under the NYC PIPS Program, an Annual Checklist Inspection is required every year starting the year after the initial filing. If your Initial Observation Report was filed in 2024 or earlier, you must complete the Annual Checklist Inspection by December 31, 2025. If your Initial Observation Report was completed in 2025, no checklist is required this year — your first Annual Checklist will be due in 2026.
The inspection must be performed by a Qualified Parking Structure Inspector (QPSI) — a New York State licensed professional engineer (PE) with relevant experience. The checklist must be based on the condition assessment from the initial inspection, kept on file, and made available to DOB upon request. It does not need to be submitted. 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 updated 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.
