Navigating New York City Local Law 11

Authored by: Rimkus Built Environment Solutions Marketing Team

A building owner discovers their NYC Local Law 11 (FISP) filing deadline passed three months ago. DOB violations and late-filing penalties may already be accumulating, while any separately identified Unsafe façade condition requires immediate public-protection measures and prompt repair.  This scenario plays out across New York City every inspection cycle, and it is often preventable with proper planning.

To protect the public and maintain a safe streetscape, the DOB requires periodic façade inspections under the Façade Inspection and Safety Program (FISP), formerly known as Local Law 11. Cycle 10 introduces updated inspection criteria, submission deadlines, and documentation expectations that building owners must follow to remain compliant.

This article covers what FISP requires and how Cycle 10 differs from earlier cycles. It also breaks down SWARMP (Safe With a Repair and Maintenance Program)  and Unsafe classifications, penalty timelines, and how to find a qualified inspector to keep a building in compliance.

Key Takeaways About Local Law 11 and FISP Compliance

Local Law 11 (FISP) requires periodic facade inspections for buildings taller than six stories, with penalties that escalate the longer a filing or repair goes unresolved.

What matters most

  • Every covered building falls into a Cycle 10 sub-cycle window based on its tax block number, each with its own filing deadline.
  • Missed filings can trigger continuing civil penalties  starting at $1,000 per month, while an unresolved SWARMP condition from a prior report may have to be reported as Unsafe in the next inspection.
  • A 2025 legislative package adds separate penalties of $5,000 to $20,000 for slow facade repairs, on top of standard FISP fines.

How to stay ahead of it

  • Engaging a Qualified Exterior Wall Inspector early avoids scheduling bottlenecks as deadlines approach.
  • Treating SWARMP conditions as a priority, rather than waiting for the next cycle, avoids automatic reclassification as Unsafe.

Rimkus supports building owners through facade inspections, repair design, and FISP compliance planning; contact us to get started.

Understanding Local Law 11

Local Law 11, now formally called FISP, requires owners of buildings taller than six stories to have their exterior walls inspected on a recurring cycle. A Qualified Exterior Wall Inspector (QEWI), a licensed Professional Engineer or Registered Architect approved by DOB, examines the facade, parapets, balconies, railings, and other exterior elements, then files a technical report classifying the building’s condition.

What NYC Local Law 11 Requires

  • Mandatory facade inspections at intervals between 6 and 12 years beginning October 1, 2026
  • Filing by DOB-assigned sub-cycle deadlines
  • Repairs of SWARMP and Unsafe conditions
  • Electronic submission through DOB NOW: Safety
  • Protective measures for hazardous facade conditions

The FISP regulatory framework

FISP rests on Article 302, Maintenance of Exterior Walls, of Title 28 of the New York City Administrative Code, with detailed requirements outlined in 1 RCNY §103-04 . DOB revised the rule on November 11, 2021, and amended it again effective December 21, 2025; owners and QEWIs typically use the current rule text and DOB guidance when preparing filings. The FISP compliance requirements guide covers what a single filing actually involves, from required documentation through DOB submission. 

All reports, including any drone photography or nondestructive-testing documentation (which supplements but does not replace the required close-up physical examination), are filed electronically through DOB NOW: Safety.

Building owners can find their property’s block number through the NYC Automated City Register Information System (ACRIS) or the DOB Building Information System (BIS) portal using the Borough, Block, and Lot (BBL) lookup. The block number’s last digit determines which sub-cycle applies; both tools are free and public.

The FISP Cycle 10 inspection period

FISP Cycle 10 is the current (10th) five-year inspection period under New York City’s Facade Inspection and Safety Program, the formal successor to Local Law 11. It commenced on February 21, 2025, and runs through February 20, 2030.

Cycle 10 Filing Deadlines by Sub-Cycle

The cycle is divided into three sub-cycles based on property tax block numbers:

Sub-CycleBlock Numbers Ending InFiling Window
10A4, 5, 6, or 9Feb 21, 2025 – Feb 21, 2027
10B0, 7, or 8Feb 21, 2026 – Feb 21, 2028
10C1, 2, or 3Feb 21, 2027 – Feb 21, 2029

This staggered approach distributes the workload for inspectors and DOB; according to NYC DOB FISP program data, approximately 17,000 buildings across all five boroughs require facade inspections each cycle. Building owners can determine their sub-cycle by looking up their property’s block number through NYC ACRIS or the DOB BIS portal; the last digit of the block number indicates which sub-cycle applies.

NYC DOB has introduced a penalty relief option for Cycle 10. Building owners whose properties show ” No Report Filed ” status from Cycle 9 and meet the criteria to certify as Safe or SWARMP may file an Initial report before their designated sub-cycle begins. This can stop the accumulation of late filing penalties going forward, though it does not eliminate previously accumulated penalties. Building owners can access this relief by submitting a Sub-cycle Override Request through DOB NOW: Safety.

Buildings requiring an Unsafe designation do not qualify for early filing. Additionally, buildings with ongoing construction work cannot be designated as Safe until construction is complete.

Cycle 10 transition rules

Cycle 9 ended February 20, 2025, and DOB no longer accepts Cycle 9 reports; buildings with No Report Filed status transition into the applicable Cycle 10 process. 

  • Early filing for Sub-Cycles 10B and 10C opened December 15, 2025, in DOB NOW: Safety, though the owner must pay all accrued civil penalties when filing that way. 
  • SWARMP conditions filed in Sub-Cycle 9A that remain unrepaired will default to Unsafe when Sub-Cycle 10A closes on February 21, 2027. 
  • Under 1 RCNY §103-04, the same condition at the same location cannot be filed as SWARMP for two consecutive cycles.

A group of buildings may file together under the filing window of any one building in the group. The owner must notify DOB at least 180 days before that window closes, and buildings that filed together in a previous cycle must continue filing under the same window.

What Local Law 11 means for building owners

Building owners bear direct statutory responsibility for Local Law 11 compliance, regardless of whether they manage properties themselves or through third parties. The law creates three primary obligations: scheduling and paying for required inspections, addressing any conditions identified in inspection reports, and filing all required documentation with DOB within specified timeframes. Owners must also post and maintain the building’s façade status in the building lobby. Following each inspection, QEWIs classify buildings into one of three categories.

Official FISP classification definitions

1 RCNY §103-04 supplies the regulatory language behind the three categories. These definitions govern how QEWIs report conditions and how DOB treats unresolved findings.

The rule defines a Safe condition as one “Not requiring repair or maintenance to sustain the structural integrity of the exterior of the building and that will not become unsafe during the next five years.”

A SWARMP condition is “safe at the time of inspection, but requires repairs or maintenance during the next five years, but not less than one year, in order to prevent its deterioration into an unsafe condition during that five-year period.”

An Unsafe condition is one that is “hazardous to persons or property and requires prompt repair. In addition, any condition that was reported as SWARMP in a previous report and that is not corrected at the time of the current inspection must be reported as an unsafe condition.”

Appurtenances covered by FISP

FISP review extends beyond flat wall surfaces. Covered exterior elements may include fire escapes, parapets, railings, balcony enclosures, flagpoles, signs, window frames, satellite dishes, antennae, and flower boxes.

What’s changing: the FISP recommendations study and Local Law 49

In May 2024, the city began a partnership to examine sidewalk-shed duration and façade-inspection requirements as part of the Get Sheds Down initiative, publishing the resulting 18-month analysis in December 2025. Local Law 49 of 2025 required DOB to study the appropriate inspection schedule and also amended the Administrative Code to require periodic exterior-wall inspections at intervals between 6 and 12 years. For newly constructed covered buildings, the law establishes the initial FISP examination in the building’s eighth year. The effective date falls during the Cycle 10B filing window and before the Cycle 10C filing window.

Local Law 49 is one piece of a larger 2025 legislative package, known as “Get Sheds Down,” that also affects façade compliance timelines. The broader 2025 ‘Get Sheds Down’ legislative package also changed sidewalk-shed and façade-repair requirements. Local Law 47 addresses shed design and aesthetics, Local Law 48 establishes 90-day sidewalk-shed permits and related penalties, Local Law 50 addresses shed lighting, and Local Law 51 establishes façade-repair milestones and penalties. See the SWARMP classification guide linked above for how these penalties interact with a SWARMP finding.

Penalties for FISP non-compliance

NYC FISP non-compliance carries substantial financial penalties established by DOB regulation. Filing penalties may continue to accrue until DOB accepts a report:

ViolationPenalty
Late filing of initial report $1,000 per month 
Failure to file initial report $5,000 per year |
Failure to correct SWARMP conditions$2,000 one-time penalty and reclassification as Unsafe 

Unsafe façade conditions carry ECB base penalties of $5,000, with maximum penalties reaching $25,000 under NYC Rules § 102-01 . Failure to correct unsafe conditions triggers ongoing $1,000 monthly penalties until acceptable amended reports confirm corrections are complete.

Beyond financial penalties, owners may face heightened regulatory scrutiny and additional enforcement action when documented façade deficiencies remain unaddressed. DOB may issue violations, mandate protective measures, or refer matters for further review when hazardous conditions are not corrected in a timely manner.

Additional consequences include mandatory sidewalk shed installation for Unsafe buildings (at high ongoing cost), potential difficulty obtaining financing or completing property transactions, and liability exposure associated with façade deterioration or deferred maintenance.

Escalating shed penalties for uncorrected Unsafe conditions

Additional linear-foot penalties increase when an Unsafe condition and its associated sidewalk shed remain unresolved over multiple years, per the schedule set out in 1 RCNY §103-04.

YearBase penaltyAdditional charge per linear foot of shed per month
Year 1$1,000 per monthNone specified 
Year 2$1,000 per month$10 
Year 3$1,000 per month$20 
Year 4$1,000 per month$30 
Year 5$1,000 per month$40 

For a long shed, the linear-foot charge can exceed the base penalty within a few years.

Deadlines after an Unsafe filing

An Unsafe filing sets a firm 90-day clock: immediate public protection and correction of all unsafe conditions, followed by an amended report within two weeks of completing repairs. The owner must immediately install public protection and correct all unsafe conditions within 90 days of filing, then submit an amended report within two weeks after completing repairs. A sidewalk shed or other public-protection measure remains in place until DOB accepts the amended report or the qualified inspector authorizes removal under the applicable requirements, and early removal may result in a $10,000 fine.

Penalty challenges and payment

An owner may submit a written challenge within 30 days after service of the violation, addressing whether the assessed civil penalty applies under the governing facts and rules. Owners pay civil penalties for Cycle 6 and later filings through DOB NOW: Safety; payment requirements may also affect whether DOB accepts certain transition filings.

FISP filing fees

DOB charges fixed filing fees separately from applicable civil penalties. The listed fees apply to initial reports, amendments, extensions, and waiver requests.

Fee type Amount
Initial filing $425.00 
Amended / subsequent filing$425.00 
Extension of time to complete repairs $305.00
Request for waiver of penalties $140.00 

FISP filing timing

Under 1 RCNY §103-04, a QEWI files the report within 60 days after completing the examination. If a QEWI does not file the report within that period, the QEWI must conduct a new examination and may not file any report more than one year after the physical examination.

Finding qualified exterior wall inspectors

Thousands of NYC buildings compete for a limited pool of qualified inspectors each FISP cycle, so engaging early within a sub-cycle window helps secure a qualified professional before demand peaks near deadlines.

QEWI candidates must hold a New York State PE or RA license and complete DOB registration. Before hiring, confirm the inspector appears on the NYC DOB Approved QEWI list, holds current licensure, has experience with similar building types and facade systems , and carries professional liability insurance.

Inspections and repairs often require access agreements with neighboring properties, which can add weeks or months to a timeline. If a building shares property lines, start those negotiations 12 to 18 months before a filing deadline.

What a QEWI keeps on file

QEWIs must maintain photographic evidence documenting required close-up inspections and retain examination records for at least six years, providing them to DOB upon request. These records can support amended reports and responses to DOB communications if a finding is ever disputed.

Managing the complete compliance cycle

Local Law 11 compliance extends beyond a single inspection: a coordinated approach covering examination, filing, repair design, and construction oversight helps owners avoid last-minute complications and repeat violations.

With 40+ years of experience and 900+ experts across 100+ offices, Rimkus identifies the root causes behind facade deterioration, not just surface conditions, so repairs address the underlying problem rather than becoming a temporary patch before the next cycle. These assessments can also feed into broader capital planning, letting owners bundle facade work with energy upgrades or other renovations to reduce cost and disruption.

Contact Rimkus to schedule an NYC facade inspection and discuss a proactive approach to FISP compliance.

Frequently asked questions about NYC Local Law 11

What happens if I miss my Cycle 10 filing deadline?

Late filings incur $1,000 per month in penalties calculated retroactively from the deadline, and building owners who file no report at all face $5,000 in annual penalties. Properties with unresolved SWARMP conditions from the previous cycle may automatically reclassify as Unsafe, triggering additional penalties and potentially requiring immediate protective measures such as sidewalk shed installation.

How do I determine which sub-cycle applies?

Building owners can determine their applicable sub-cycle by looking up their property’s block number through NYC ACRIS or the DOB BIS portal using the Borough, Block, and Lot (BBL) search. The last digit of the block number indicates the applicable sub-cycle: properties ending in 4, 5, 6, or 9 fall under Sub-Cycle 10A; those ending in 0, 7, or 8 fall under 10B; and those ending in 1, 2, or 3 fall under 10C.

What qualifications must a QEWI inspector have?

QEWIs must hold a current New York State Professional Engineer (PE) or Registered Architect (RA) license and complete registration with the NYC Department of Buildings before performing FISP inspections. Building owners should verify that prospective inspectors appear on the NYC DOB Approved QEWI list and maintain professional liability insurance coverage.

This article is intended to provide general information and insights into prevailing industry practices. It is not intended to constitute, and should not be relied upon as, legal, technical, or professional advice. The content does not replace consultation with a qualified expert or professional regarding the specific facts and circumstances of any particular matter.