NYC lead paint turnover work and the July 1, 2027 child-under-6 deadline

What work is required

• Peeling paint and underlying defects (such as leaks): at minimum, wet scrape and repaint.
• Chewable surfaces with bite marks: remove the lead-based paint, or encapsulate with an approved hard, puncture-resistant encapsulant applied by certified contractors.
• Door and window friction surfaces: remove the lead-based paint from window sashes and frames and from all door and door-frame friction surfaces, even if the paint is intact, unless previously abated. This can mean replacing the door and frame.
• Floors, sills and wells: make all bare floors, windowsills and window wells smooth and cleanable.

All work must follow safe work practices (HPD).

Turnover (vacant apartment)

• A turnover happens every time a unit becomes vacant and a new tenant will move in, whether or not the new tenant has a child.
• Finish the work before the new tenant takes occupancy, and certify it on the Lease/Commencement of Occupancy Notice for Prevention of Lead-Based Paint Hazards, given with the lease and at lease renewal, together with the Lead Paint Hazards in the Home pamphlet. Give the tenant documentation on request.
• Friction-surface work missed at the first turnover must be done at the next turnover, or when the child-under-6 rule applies.
• Lead-free exemptions granted under the old 1.0 mg/cm² standard are automatically revoked at the next turnover, and owners must notify HPD of the vacancy.

From HPD.

Child-under-6 units: when the 3-year clock starts

A child-under-6 unit is one where a child under 6 routinely spends 10 or more hours a week. The 3-year period begins when the owner learns of the child through the Annual Notice, a lease or renewal, written tenant notice, or any other actual knowledge. Tenants are required to tell owners when a child under 6 begins residing in the unit (HPD).

Relocation and records

• If the work can’t be done safely with occupants in residence, the owner must provide temporary relocation to appropriate housing (Admin. Code § 27-2056.11(a)(1); 28 RCNY § 11-06, as quoted by HPD). If a tenant refuses, document your good-faith efforts.
• Keep turnover inspection records, documentation of all work, contractor certifications and safe-work documentation, plus records of attempts to schedule work, for at least 10 years.
• HPD says failure to meet the work or record-keeping requirements can result in Class C immediately hazardous violations.

From HPD. Questions: HPD Lead Information Line, 212-863-5501.

Plan for July 1, 2027 (our suggestion)

1. List every unit where your Annual Notices or leases showed a child under 6 as of Jan. 1, 2025.
2. Check which of those units already had door and window friction surfaces abated.
3. Get certified-contractor bids and schedule the rest well before July 1, 2027, allowing time for relocation if needed.
4. For children identified after Jan. 1, 2025, record the date you learned of the child and set a 3-year reminder.

Our checklist suggestion for staying organized, not an official form.

Track lease notices, inspections and renewal dates for each unit in our free deadline tracker.

Free deadline tracker For property managers

What is the July 1, 2027 lead paint deadline in NYC?

For any unit where a child under 6 resided as of January 1, 2025, NYC owners must complete abatement-level lead work, including door and window friction surfaces, by July 1, 2027, unless it is triggered sooner by a turnover (NYC HPD).

Do NYC owners have to abate windows and doors even if the paint is not peeling?

Yes. HPD says owners must abate door and window friction surfaces even if the paint is intact, unless the surfaces were previously abated.

When must NYC turnover lead work be done?

Before the new tenant takes occupancy. Owners certify completion on the Lease/Commencement of Occupancy Notice given with the lease (NYC HPD).

When does the 3-year child-under-6 clock start in NYC?

When the owner learns a child under 6 resides in the unit, through the Annual Notice, a lease or renewal, written tenant notice, or other actual knowledge (NYC HPD).