Fall is one of the busiest compliance seasons for NYC condos and co-ops. From façade inspections to cooling tower requirements and energy planning, boards face obligations that carry steep fines if missed. Even when deadlines feel far away, the reality is that planning, inspections, and budgeting need to start now to avoid contractor backlogs, inflated costs, and the added difficulty of scheduling work once winter weather sets in.
Here’s what every board should be focused on this fall.
Façade safety inspections (Local Law 11 / FISP)
Cycle 10 of the Facade Inspection Safety Program (FISP) began on February 21, 2025. All buildings six stories or taller must file an inspection report once every five years, and deadlines are based on block numbers.
- Sub-cycle 10A (block numbers ending in 4, 5, 6, or 9): filing window runs Feb 21, 2025 through Feb 21, 2027.
- Sub-cycles 10B and 10C will follow in staggered two-year windows through 2031.
Even though the first Cycle 10 deadline (10A) is more than a year away, boards should act now. Early inspections identify repair needs, help secure contractors before demand spikes, and allow enough time to budget. Waiting until 2026 could mean paying premium prices for rushed work or missing the filing window altogether.
Cooling towers (Local Law 77)
Cooling towers must be tested for Legionella bacteria every 30 days during the cooling season, April 1 through October 31. After shutdown, towers must be cleaned and disinfected, with documentation kept on file.
In light of recent Legionnaires’ outbreaks, the City is moving toward stricter enforcement. Proposed changes would require even more frequent testing, and inspectors are already scrutinizing logs and records. Boards that stay on top of their documentation now will avoid costly violations later.
Energy benchmarking and Local Law 97 prep
Local Law 97, the city’s ambitious carbon emissions law, is now in effect. Buildings that exceed emissions caps will face significant fines beginning in 2025. That makes this fall a critical planning season.
- Benchmarking filings for 2024 data were extended to June 30, 2025, with further extensions available through late summer.
- Even if your building filed on time, use the fall to review results, meet with engineers, and model whether you’re on track for compliance.
- Energy retrofits and upgrades take time to design and fund. Starting now avoids rushed, expensive projects later.
Other fall must-dos
- Boilers and heating systems. Inspections and tune-ups should be completed before the first cold snap. An outage in January costs far more than a fall checkup.
- Elevators. Annual inspections and tests are typically scheduled in the fall. Confirm dates with your management company to avoid violations.
Why boards need to act now
Even when deadlines are months or years away, boards benefit from starting early:
- Contractor availability. Waiting until filing windows close means competing with hundreds of other buildings for the same engineers and contractors.
- Budget planning. Inspections often uncover repair needs. Building those into budgets early avoids emergency assessments.
- Avoiding premium costs. Last-minute projects are almost always more expensive.
- Resident communication. Early planning gives time to prepare residents for scaffolding, disruptions, or fee increases.
What your board should do this fall
- Confirm which Local Laws apply to your building.
- Identify your façade sub-cycle and schedule inspections early.
- Keep cooling tower testing logs current and plan for end-of-season cleaning.
- Review energy data and start Local Law 97 planning with your engineers.
- Schedule boiler and elevator inspections before year-end.
- Communicate upcoming projects and potential costs with residents.
👉 For a broader overview, see our explainer on NYC’s most important Local Laws.
