The rule, in one sentence.
Local Law 31 of 2020 required every pre-1960 dwelling unit in NYC — whether occupied by a child or not — to be XRF-inspected for lead-based paint by August 9, 2025. The five-year window expired this summer.
Why LL31 mattered beyond LL1.
Local Law 1 of 2004 already required annual lead investigation in pre-1960 apartments where a child under six resided. LL31 widened the net dramatically — to every pre-1960 unit, regardless of occupancy. For many portfolios, that turned a focused annual program into a comprehensive one-time XRF survey of the entire pre-1960 stock.
What HPD is doing now that the deadline has passed.
HPD has signalled a phased enforcement posture. Inspectors performing routine LL1 visits ask for the LL31 inspection record; portfolios without it are generating new violations. Sale-stage and refinance-stage due diligence is also flagging units that lack documentation.
From our active engagements over the past several weeks:
- Class C lead violations are being filed where investigators find lead and no LL31 record on file.
- Some HPD inspectors are issuing administrative notices for the missing inspection itself, separate from any lead finding.
- Lenders and transactional counsel are routinely asking for LL31 documentation on pre-1960 building diligence.
If your portfolio missed the deadline.
The right move is to schedule the catch-up XRF survey quickly and document the program — survey scope, completion dates, inspector certifications, results — in a way HPD or a buyer's counsel can read in one sitting. Multi-building portfolios benefit from a single consolidated report packaged at the portfolio level, with per-unit detail attached.
Documentation HPD expects to see.
For each unit:
- XRF readings per component, with calibration log attached
- Inspector's EPA Lead-Safe certification and HUD-protocol training
- Plain-English summary of positive components, if any
- Photographic record of friction and impact surfaces
If you need to mobilize fast — a 20-unit pre-1960 building can be surveyed and reported in under a week — we'll scope it on a single call.