Staying Ahead of NYC Building Requirements

At Milrose, together with our partners at HLZAE, we are committed to helping building owners, managers, and stakeholders stay fully compliant with NYC Department of Buildings regulations. As we move toward the end of 2025 and begin preparing for 2026, we encourage our clients to review the upcoming requirements and deadlines that may affect their properties.

Our combined teams support every phase of the compliance process, including inspections, reporting, filings, and long-term planning. Our goal is to keep your buildings safe, compliant, and protected from costly penalties.

FISP (Facade Inspection and Safety Program) – Cycle 10

The FISP Cycle 10 filing period is underway. Window 10A is currently open through February 21, 2027 for buildings with block numbers ending in 4, 5, 6, or 9. With additional filing windows scheduled to open in the coming years, early planning is essential.

Proactive coordination helps our clients avoid delays, manage repair needs, and stay compliant throughout the entire cycle.

Key Information:

• Window 10B opens February 21, 2026 for block numbers ending in 0, 7, or 8
• If your Cycle 9 report has not been filed, Cycle 10 may be submitted at any time to prevent further penalties
• Cycle 10 runs from February 21, 2025 through February 21, 2030

Parapet Inspections

Annual parapet inspections are required for all buildings fronting a public right-of-way, aside from 1 or 2 family homes.

Requirements:

• Compliance deadline: December 31, 2025
• Reports must be kept on-site for six years for potential DOB audit
• Inspections are required every year and should be built into your annual maintenance strategy

Our team can assist with annual parapet inspections and ensure your documentation is complete and ready for review.

Local Law 87 (Energy Efficiency Report)

Local Law 87 requires certain buildings to submit an Energy Efficiency Report and Retro-commissioning report every ten years. Missing the filing deadline results in a $3,000 penalty for the first year and $5,000 for each year after.

Key Updates:

• We recommend securing your LL87 service provider one to two years before your filing deadline
• Owners must submit their EER and RCx Report by December 31 of the year due
• This year's filing deadline is extended to March 31, 2026 for buildings with tax blocks ending in 5
• Buildings with tax blocks ending in 6 should begin securing their provider now, as evaluations must occur during both winter and summer seasons

Energy Label Posting Requirements (LL87 and LL33)

Local Law 87 Energy Label Reminder

Buildings that benchmark 2024 energy data must post their Building Energy Efficiency Rating Label between December 1 and December 31, 2025. This is a temporary shift from the usual October timeline.

Failure to download and post the label may result in a $1,250 penalty.

Local Law 33 Update

DOB has postponed the availability and deadline for the 2025 Building Energy Efficiency Rating Labels to December 31, 2025.

Local Law 97 (Carbon Emissions Limits)

If your building missed the LL97 filing deadline, it is important to take action now. While the extended deadline has passed, viable pathways remain for reducing exposure to penalties and moving toward compliance.

Key Points:

• Filed extension deadline: December 31, 2025
• Mediated resolutions and Good Faith Effort pathways remain available
• The Annual Carbon Emissions Report for calendar year 2025 is due May 1, 2026
• Reports must be filed through BEAM and certified by a Registered Design Professional
• Buildings must comply with emissions limits to avoid fines

Milrose and HLZAE support clients with LL97 filings, compliance strategies, and multi-year planning. We also offer discounted services for Local Law 88 lighting and submetering filings and Local Law 84 energy and water benchmarking.

PIPS (Parking Structure Inspections) – Local Law 126

The LL126 inspection window remains open and timely action is critical.

Key Details:

• Current filing window (Sub Cycle 1B): Manhattan Community Districts 8 through 12 and all Brooklyn districts
• PIPS report deadline: December 31, 2025
• Initial observations were due August 1, 2024 and late submissions may result in penalties
• Annual observations are required and must be kept on-site
• Next filing window, Sub Cycle 1C, opens January 1, 2026 for the Bronx, Queens, and Staten Island
• Penalty for missing the deadline is $2,500

How Milrose and HLZAE Can Support You

Milrose and HLZAE work as your trusted partners throughout every stage of the compliance process. Whether you are preparing for upcoming deadlines, planning inspections, or navigating multi-year building compliance, our teams are here to guide you.

If you have questions about any of the requirements above or would like support preparing for 2026, we invite you to connect with us. We are committed to helping you maintain safe, compliant, and future-ready buildings.