Local Law 11 / FISP
Local Law 11 / FISP
Façade inspection, compliance filing, and repair coordination for New York City buildings subject to the Façade Inspection Safety Program. Post & Lintel supports building owners, co-op and condo boards, and property managers through every phase of FISP compliance — from initial assessment through DOB filing and repair close-out.
Local Law 11 is one of New York City's most consequential building maintenance requirements — and one of the most commonly misunderstood.
The Façade Inspection Safety Program (FISP), enacted as Local Law 11 in 1998, requires that all New York City buildings taller than six stories undergo a close-range critical examination of their exterior walls and appurtenances every five years. The program is governed by Article 302 of Title 28 of the NYC Administrative Code and detailed in DOB Rule 1 RCNY §103-04.
The law traces its origins to Local Law 10 of 1980, which was enacted after a Barnard College student was killed by a piece of masonry falling from a Manhattan building. Over four decades, the program has grown into a comprehensive inspection and reporting framework covering an estimated 16,000 buildings across all five boroughs each cycle.
Who Is Subject to FISP
FISP applies to all buildings greater than six stories in height located anywhere within New York City's five boroughs — Manhattan, Brooklyn, Queens, The Bronx, and Staten Island — regardless of occupancy type. This includes residential co-ops and condominiums, rental apartment buildings, commercial office buildings, hotels, mixed-use properties, and institutional structures. It is ultimately the building owner's responsibility to determine whether their building is subject to the program.
Current Cycle: 2025 – 2030
FISP Cycle 10 commenced on February 21, 2025 and runs through February 21, 2030. As in prior cycles, Cycle 10 is divided into three sub-cycles to stagger filing deadlines and distribute workload across the inspection and contracting community. A building's sub-cycle is determined by the last digit of its block number, which can be verified through the NYC Automated City Register Information System (ACRIS) or the DOB Building Information System (BIS) portal.
| Sub-Cycle | Block Number (Last Digit) | Filing Window | Note |
|---|---|---|---|
| 10A | 4, 5, 6, or 9 | Feb 21, 2025 – Feb 21, 2027 | Unresolved Cycle 9A SWARMP conditions default to Unsafe at close of 10A window |
| 10B | 0, 7, or 8 | Feb 21, 2026 – Feb 21, 2028 | Sub-cycle 10B filing window is now open |
| 10C | 1, 2, or 3 | Feb 21, 2027 – Feb 21, 2029 | Early engagement recommended given inspector availability constraints |
Cycle 10 Amnesty Program
The NYC DOB has introduced a limited amnesty provision for buildings that did not file FISP reports in prior cycles. During the Sub-cycle 10A window, buildings with a "No Report Filed" status from previous cycles may file early Cycle 10 reports for Sub-cycles 10B and 10C, stopping the accumulation of late filing penalties going forward. Previously accrued penalties are not eliminated by this program. Building owners with outstanding prior-cycle violations should consult directly with the DOB or a licensed professional regarding their specific circumstances.
New in Cycle 10
Cycle 10 includes updated requirements compared to prior cycles, reflecting DOB's continued evolution of the program. Notable areas of change include updated walls examination requirements, heightened scrutiny of balcony enclosures and guard railings, revised documentation standards for reporting, and an updated enforcement posture regarding outstanding SWARMP conditions from prior cycles. Building owners and managers should not assume that prior-cycle procedures apply without review.
Safe, SWARMP, and Unsafe
After performing the required critical examination, the Qualified Exterior Wall Inspector (QEWI) classifies the building's façade condition using one of three designations defined in DOB Rule 1 RCNY §103-04. Each classification carries distinct compliance obligations and timelines.
Safe
The exterior wall and all appurtenances are in sound condition, require no repair or maintenance, and are not expected to become unsafe within the next five years. No further action is required until the next inspection cycle.
SWARMP
Safe With a Repair and Maintenance Program. The façade is currently safe but has conditions that require repair within the five-year period — no sooner than one year after filing — to prevent deterioration into an Unsafe classification. Unresolved SWARMP items are automatically reclassified as Unsafe when the next cycle's filing window closes, regardless of actual physical condition at that time.
Unsafe
The façade has conditions posing an immediate hazard to persons or property. Upon an Unsafe classification, the building owner must immediately install protective measures — typically a sidewalk shed — and complete remediation within 90 days. An amended FISP report must be filed within approximately two weeks of repair completion. Extensions may be requested from the DOB if repairs cannot be completed within the prescribed timeframe.
The SWARMP-to-Unsafe Escalation
A critical compliance issue that many building owners encounter: SWARMP conditions identified in a prior cycle that remain unrepaired at the time of the next cycle's filing are automatically reclassified as Unsafe — regardless of whether the physical condition has worsened. This automatic reclassification triggers the full Unsafe penalty and protective measures structure. Owners should treat SWARMP conditions as active compliance obligations, not deferred items.
Qualified Exterior Wall Inspectors (QEWIs)
FISP inspections may only be conducted, witnessed, or supervised by a Qualified Exterior Wall Inspector. Only QEWI-filed reports are accepted by the DOB. Building owners cannot self-file, and general contractors or unlicensed professionals cannot perform or certify the inspection.
Who Qualifies as a QEWI
A QEWI must be a New York State licensed Professional Engineer (PE) or New York State Registered Architect (RA) in good standing, with at least seven years of relevant experience in the design, installation, or inspection of exterior walls. QEWIs must be approved and registered with the NYC DOB before they are authorized to file FISP reports. Personnel working under a QEWI's direct supervision must have a minimum of three years of relevant experience with a bachelor's degree in architecture or engineering, or five years without the degree.
What the Critical Examination Involves
FISP inspections are not visual surveys from the street. The critical examination requires close-range physical access — within arm's reach — of all exterior façade elements. This typically requires scaffolding, suspended access equipment (such as a swing stage), rope access, or other means to bring the inspector into direct contact with the building surface at regular intervals. The inspection covers all exterior walls facing a street or public right-of-way, as well as all appurtenances including:
- Masonry walls and cladding systems
- Parapets and copings
- Balconies and terraces
- Guard railings and balcony enclosures
- Windows and window anchors
- Fire escapes and attached metalwork
- Lintels, sills, and spandrels
- Cornices and decorative elements
- Façade caulking and sealants
- Water-tightness conditions
- Greenhouses and roof structures
- Any attached exterior appurtenances
How FISP Compliance Works
Compliance with FISP involves several coordinated steps, from confirming applicability through inspection, filing, repair execution, and amended report submission. The sequence below reflects the standard path for a building that is current with prior-cycle obligations.
Penalties for Non-Compliance
FISP non-compliance carries a structured penalty regime administered through the NYC Environmental Control Board (ECB). Penalties begin accruing immediately upon missed deadlines — there is no grace period. DOB violations are issued automatically and the penalty structure escalates over time.
Assessed from the first day after the filing deadline is missed. Calculated retroactively. Penalties accrue monthly until an acceptable report is filed.
Annual penalty for buildings with no FISP report on file. Accumulates in addition to monthly late filing penalties.
Base ECB penalties for Unsafe façade conditions under NYC Rules §102-01, with maximum penalties reaching $25,000 depending on violation severity.
Ongoing monthly penalties for unresolved Unsafe conditions, plus additional scaffold-related penalties based on the amount of protective equipment required.
Beyond Financial Penalties
The financial penalties above represent only part of the non-compliance exposure. Buildings with Unsafe classifications face mandatory sidewalk shed installation and maintenance, which can run $10,000–$20,000 per month for larger buildings. Unsafe conditions also create civil liability exposure in the event of injury or property damage, may complicate financing and insurance renewals, and can result in heightened DOB regulatory scrutiny on other open matters affecting the building.
SWARMP Escalation Costs
SWARMP conditions that are allowed to lapse into Unsafe status typically result in substantially higher repair costs than if addressed proactively — both because the underlying conditions will have worsened, and because the Unsafe classification adds immediate sidewalk shed requirements and enforcement overhead. Proactive repair planning within the SWARMP timeline is generally the more cost-effective path.
Façade Repair and Restoration
For many buildings, the FISP inspection is the beginning of a repair and restoration process, not the end of the compliance obligation. The scope, cost, and timeline of repair work varies significantly depending on building age, construction type, and the nature of the conditions identified.
Common Façade Conditions Identified Under FISP
- Spalled or cracked brick masonry
- Deteriorated mortar joints (repointing)
- Failed caulking and sealants
- Corroding lintels and shelf angles
- Cracked or loose terra cotta
- Leaking or failed window perimeters
- Deteriorated balcony slabs or railings
- Parapet instability or cracking
- Loose or unstable fire escape attachments
- Water infiltration and staining
- Failing expansion joints
- Corroding embedded steel
Permits and DOB Filing for Repair Work
The FISP inspection itself does not require a permit. However, most façade repair work — particularly structural masonry repairs, lintel replacements, balcony restorations, and window work — does require a DOB permit prior to construction. Post & Lintel coordinates repair-related DOB filings alongside the FISP process, including preparation of signed and sealed repair drawings where required.
Scaffolding and Access Equipment Permits
Installation of sidewalk sheds, scaffolding, and suspended access equipment each require separate DOB permits. These permits must be in place before access equipment is erected. For buildings with Unsafe conditions, the sidewalk shed permit is part of the immediate compliance response and must be obtained promptly.
Post & Lintel FISP Services
Post & Lintel supports building owners and property managers across all phases of the FISP compliance process. Field observations and documentation work may be performed by trained personnel; all regulated evaluations, classifications, and DOB filings are performed by appropriately licensed professionals.
- FISP eligibility and sub-cycle determination
- Prior-cycle report review and gap analysis
- QEWI coordination and critical examination
- Close-range façade observation
- Condition documentation and photography
- FISP report preparation and DOB NOW filing
- SWARMP repair scope and scheduling
- Unsafe condition response coordination
- Sidewalk shed and access equipment permitting
- Façade repair drawings and DOB filing
- Masonry and waterproofing coordination
- Contractor bid and scope review
- Construction observation support
- Amended report filing upon repair completion
- Violation removal coordination
- Multi-cycle compliance planning
Who We Work With
Post & Lintel has supported FISP compliance work across a range of building types and ownership structures throughout New York City's five boroughs.
Landmarked Buildings and LPC
Buildings within NYC Landmarks Preservation Commission (LPC) jurisdiction require LPC approval for any exterior repair or alteration work before a DOB permit can be issued. This adds an additional step to the FISP repair process for landmarked buildings and those in designated historic districts. Post & Lintel coordinates LPC submissions where required as part of the repair permitting process.
Frequently Asked Questions
How do I find my building's sub-cycle?
Look up the last digit of your building's block number through NYC ACRIS (acris.nyc.gov) or the DOB Building Information System (BIS) portal using your Borough, Block, and Lot (BBL). The last digit determines whether your building falls in Sub-cycle A, B, or C.
What happens if I missed a prior cycle?
Buildings with no FISP report on file from prior cycles have been accruing late filing and failure-to-file penalties. In Cycle 10, a limited amnesty provision allows these buildings to file early for Sub-cycles 10B or 10C during the 10A window to stop further accumulation of penalties — but previously accrued penalties are not automatically waived.
Does a new building owner inherit FISP obligations?
Yes. FISP obligations run with the building, not the owner. A new owner assumes responsibility for any open FISP violations, outstanding SWARMP repair obligations, and upcoming filing deadlines regardless of prior ownership. Due diligence on FISP compliance status is recommended when purchasing any building subject to the program.
Can FISP be filed without scaffolding?
The critical examination requires close-range physical access — within arm's reach — of all inspected surfaces. Ground-level observation or binoculars alone do not satisfy the DOB's requirements. Scaffolding, suspended access equipment, or rope access is typically required, depending on the building and the inspection methodology.
How long does a FISP inspection take?
The timeline depends significantly on building size, height, façade complexity, and the extent of access equipment required. For larger buildings, the full process from access setup through report filing can span several months. Engaging a QEWI early in the sub-cycle window is recommended.
Do FISP repairs require a DOB permit?
The inspection itself does not require a permit. However, most structural and significant façade repair work requires a DOB permit and signed and sealed drawings. Access equipment — scaffolding and sidewalk sheds — also requires its own permit before installation.
What does a FISP report cost?
Inspection fees vary based on building size, height, complexity, and façade condition. For a typical co-op or condo building in Manhattan, inspection and filing costs may range from several thousand to twenty-five thousand dollars or more. Repair costs, where required, vary significantly and are assessed separately based on the scope of work identified.
Does FISP overlap with Local Law 97?
While FISP focuses on structural safety, façade assessment work sometimes surfaces conditions related to energy performance — particularly window conditions, thermal bridging, and air infiltration. These findings may be relevant to Local Law 97 compliance planning. Post & Lintel can assist with coordinating both compliance streams where applicable.
Not sure where your building stands? Reach out to discuss your sub-cycle, prior filings, and next steps.
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