Last updated: April 2026
The primary testing deadline under NYC Local Law 31 passed on August 9, 2025. If your building was covered and you haven’t completed the required XRF inspections, you’re not behind on a deadline — you’re in the enforcement phase.
That’s a different situation than missing a filing date. HPD is now moving from compliance tracking to active enforcement for property owners who haven’t completed required testing and submitted results through the HPD portal.
For property owners who have completed testing, the work isn’t finished. Annual tenant notification, hazard correction, documentation, and clearance testing for any remediation are ongoing obligations under LL31.
This guide explains how lead-based paint inspections work in NYC, what the thresholds mean, what XRF testing actually does, and what full compliance looks like as of 2026.
Who Local Law 31 Covers and What It Requires
NYC Local Law 31 applies to pre-1960 rental buildings and rental units in buildings constructed between 1960 and 1978 where a child under 6 lives or has lived — with expansions that have broadened coverage over time. The law requires XRF inspection of all painted surfaces in covered rental units.
Key scope elements:
- Building age threshold: Pre-1960 buildings are the core coverage group. Some 1960–1978 buildings are also covered based on occupancy and child residency conditions.
- Unit-based, not tenant-based: LL31 is a building-based obligation. The inspection requirement applies to covered units regardless of whether a child currently lives there. Waiting for a child to move in before testing is not compliant.
- Owner-occupied 1–2 family homes are generally exempt from LL31 XRF testing requirements. This exemption applies to owner-occupied residential use; landlords in the same building type are not exempt.
- Enforcement agency: HPD. Violations carry significant civil penalties. Because HPD updates its penalty schedule periodically, check HPD’s current schedule for current figures rather than relying on any static number cited online.
The core LL31 requirement is straightforward: get every painted surface in every covered unit inspected by an EPA-certified lead inspector or risk assessor using XRF technology, and submit results to HPD via the HPD Online portal.
As of 2026, that testing deadline has passed. The question for most covered property owners is not “when do I need to do this” — it’s either “I did it, what comes next” or “I haven’t done it yet, what do I do now.”
How XRF Lead Paint Inspection Works
XRF stands for X-ray fluorescence. It’s the standard testing method for LL31 compliance because it’s non-destructive, fast, and produces results on-site without requiring samples to be sent to a lab.
Here’s how the process works:
The inspector brings a handheld XRF analyzer — a device roughly the size of a thick flashlight. It’s placed against each painted surface to be tested. The device emits a brief X-ray pulse that excites the lead atoms in the paint. The fluorescent X-rays emitted back are measured and interpreted as a lead concentration reading in milligrams per square centimeter (mg/cm²).
Each surface gets its own reading. Under LL31, the inspector tests every distinct painted component in the unit — walls, doors, door frames, window sills, window troughs, baseboards, radiators, and more. In a pre-war apartment with original trim, that’s easily 50 to 100 individual readings per unit.
Results are recorded on-site and documented in a report that identifies each tested surface, its location, and the XRF reading. That report is then uploaded to HPD’s portal.
The inspection must be conducted by an EPA-certified lead inspector or risk assessor. That’s a federal credential requiring training and examination. Not every environmental consultant is EPA-certified for lead work — confirm credentials before engaging anyone for LL31 compliance.
The XRF process typically takes 1 to 3 hours per unit depending on size and complexity. Most property owners receive their report within 2 to 3 business days of the inspection.
Lead Paint Thresholds: What the Numbers Mean
Lead-based paint isn’t a binary finding. Results fall into ranges that carry different regulatory implications.
The NYC threshold for LL31 enforcement is 0.5 mg/cm² by XRF. A surface reading at or above this level is classified as lead-based paint under HPD’s Local Law 31 framework. This is more stringent than the federal EPA threshold of 1.0 mg/cm² used for EPA RRP work.
The federal threshold of 1.0 mg/cm² applies under EPA RRP rule contexts — for example, when contractors perform renovation work in pre-1978 housing. The same surface can be “lead-based” under NYC’s LL31 at 0.5 mg/cm² while technically below the federal action threshold. For NYC compliance, HPD’s 0.5 mg/cm² threshold governs.
Laboratory paint chip analysis uses a different metric: 0.5% lead by weight. This method involves collecting a chip of paint down to the substrate and submitting it for analysis. XRF is the required method for LL31 proactive inspection — chip sampling is used as a supplement when XRF results are inconclusive.
Dust wipe clearance standards apply after any lead hazard correction or remediation work. Current HUD/EPA clearance thresholds, which HPD aligns with, are:
- 10 µg/ft² for floors
- 100 µg/ft² for interior window sills
- 400 µg/ft² for window troughs
These standards apply to post-abatement clearance testing — they confirm that lead hazards have been adequately corrected before the unit is reoccupied.
| Standard | Threshold | Context |
|---|---|---|
| NYC HPD / LL31 | 0.5 mg/cm² (XRF) | LL31 proactive inspection |
| EPA / Federal | 1.0 mg/cm² (XRF) | EPA RRP renovation contexts |
| Lab chip analysis | 0.5% by weight | Supplemental / inconclusive XRF |
| Floor clearance (dust) | 10 µg/ft² | Post-remediation clearance |
| Window sill clearance | 100 µg/ft² | Post-remediation clearance |
| Window trough clearance | 400 µg/ft² | Post-remediation clearance |
What Happens When Lead-Based Paint Is Found
Finding lead-based paint in your building doesn’t automatically mean you have a violation. It means you have a documented condition that requires a management response.
Intact lead-based paint that’s in good condition — well-adhered, not deteriorating, not being disturbed — may be managed in place under LL31 with appropriate notification and monitoring. The law requires annual distribution of HPD’s lead paint notice to tenants in covered units where LBP is present, and record-keeping of those notices.
Deteriorated lead-based paint — peeling, chipping, flaking, or with surface damage — triggers a correction obligation. Under the NYC Housing Maintenance Code, a Class B violation for deteriorated LBP carries a 30-day correction period. Failure to correct within that period results in daily fines.
Correction of lead hazards requires a licensed lead abatement contractor using lead-safe work practices. After abatement, a clearance inspection must be conducted — dust wipe samples collected and analyzed at an accredited lab, confirming surfaces meet the clearance thresholds above. UNYSE conducts the initial LL31 inspection and post-abatement clearance testing; abatement is performed by a separate licensed contractor, maintaining the independence that LL31 and EPA RRP require.
HPD Online portal submission is required for LL31 inspection results. The inspector’s report and attestation are uploaded through the portal. HPD uses this data to track compliance and identify buildings where required inspections haven’t been completed.
One thing that surprises property owners regularly: the annual notice obligation continues indefinitely for units where lead-based paint is present. It’s not a one-time filing. HPD’s notice form must be distributed to affected tenants each year, signed copies retained, and records kept available for HPD inspection.
Ongoing LL31 Obligations in 2026
The testing deadline passed. Here’s what LL31 compliance looks like on an ongoing basis:
If you completed required testing and found no lead-based paint: Maintain your documentation. Keep inspection reports accessible. No annual notice is required in units confirmed free of LBP.
If you completed testing and found lead-based paint: Annual distribution of HPD’s lead paint notice to tenants in affected units is required. Keep signed copies of all notices. Monitor paint condition and address deterioration promptly.
If you completed testing, found LBP, and had correction work done: Confirm your clearance testing was completed and results were filed with HPD. If abatement work was done without clearance testing, that step still needs to happen. HPD considers the correction incomplete until clearance testing confirms hazards have been remediated.
If you haven’t completed required testing yet: Engage a certified lead inspector now. HPD’s enforcement activity is increasing. The cost of completing required testing is significantly lower than HPD civil penalties and the complications of an HPD violation on the property record.
When a new child under 6 moves in: LL31 requires an updated inspection within one year of a child under 6 moving into any covered unit — regardless of when the last inspection was conducted.
What a Lead Paint Inspection Costs in NYC
Lead paint inspections in NYC using XRF typically cost $400 to $1,200 per unit depending on unit size, number of painted components, and building logistics.
What affects where you fall in that range:
- Unit size. More rooms and surfaces mean more XRF readings and more time on-site.
- Building-wide scheduling. Multi-unit inspections scheduled together are more efficient than single-unit bookings. Per-unit costs often decrease when multiple units are done in the same visit.
- Building age and trim complexity. Pre-war apartments with original ornate trim, multiple door frames, and detailed window surrounds have more surfaces to test than a post-war unit with minimal millwork.
- Report turnaround requirements. Standard delivery takes 2 to 3 business days. Expedited options are available when HPD compliance timelines are pressing.
For full building assessments covering 20, 50, or 100+ units, per-unit costs decrease with scale. UNYSE has managed LL31 compliance programs across large multifamily portfolios in Manhattan and Brooklyn and can structure assessments around building access schedules and tenant coordination.
Frequently Asked Questions
What is a lead-based paint inspection under Local Law 31?
A Local Law 31 lead-based paint inspection is a surface-by-surface XRF assessment of all painted components in a covered NYC rental unit, conducted by an EPA-certified lead inspector or risk assessor. The inspector tests every painted surface in the unit and documents results in a report submitted to HPD via the HPD Online portal. The inspection establishes whether lead-based paint is present and where, which determines the owner’s ongoing management or correction obligations.
Does finding lead paint in my building mean I have a violation?
Not automatically. Lead-based paint that is intact and not deteriorating does not constitute an HPD violation by itself. Deteriorated lead-based paint triggers a correction obligation and can result in a Class B violation with a 30-day correction period. Your inspection report documents the condition of each surface and guides the appropriate response.
Can the same inspector do the testing and the abatement?
No. Lead hazard correction under LL31 must be performed by a licensed lead abatement contractor separate from the inspector. Clearance testing after abatement must also be conducted by a separate third party. This separation prevents conflicts of interest and ensures clearance results are independent. UNYSE conducts inspections and clearance testing; abatement is done by a licensed contractor of the owner’s choosing.
What is the LL31 testing deadline in 2026?
The primary LL31 testing deadline was August 9, 2025. As of 2026, LL31 is in the enforcement phase for buildings that haven’t completed required inspections. If you haven’t completed testing for your covered units, the right step is to engage a certified lead inspector now and submit results through HPD Online.
How long does a lead paint inspection take per unit?
A typical NYC apartment takes 1 to 3 hours for the on-site XRF inspection depending on size and the number of painted components. The written report is typically delivered within 2 to 3 business days. For multi-unit buildings, inspections can often be completed across a full building within a week depending on access.
If you need LL31 inspection for one unit or a full building, UNYSE conducts XRF inspections across all five boroughs with report turnaround coordinated to HPD portal submission timelines.
Schedule your lead inspection or see what XRF testing costs for your building.