New York City Local Law 97 Deadline: May 1, 2025 

April 8, 2025

As previously advised, the first compliance report required under New York City’s Local Law 97 (LL97) is due by May 1, 2025. LL97 requires most buildings over 25,000 square feet to limit carbon emissions or face significant penalties, including condominiums (condos) and cooperatives (coops). 

Having difficulty meeting that deadline?

Don’t fret. There is a 60-day grace period through June 30, 2025 to timely file without penalty. Additionally, building owners have between now and June 30, 2025 to apply in the reporting portal for an extension to the reporting deadline until August 29.

Still have concerns about compliance?

We can assist boards of condos or coops in evaluating their exposure and providing guidance on how best to mitigate it, including, but not limited to, assessing whether to buy Renewable Energy Credits or Certificates (i.e., RECs) in lieu of compliance as an alternative. New York City also developed the NYC Accelerator, a free program designed to help building owners and operators navigate LL97 compliance.

Unsure how to enforce LL97 requirements under the governing documents against unit owners (residential or commercial)?

We can also help boards interpret their governing documents and fashion innovative solutions that allow implementation in any type of condo or coop.

Failure to comply with the deadlines and requirements of LL97 may result in fines of $0.50 per square foot per month for failing to file a report and $268 per metric ton of CO2 equivalent that exceeds a building’s assigned limit. Making a false statement on an annual report may result in fines of up to $500,000 and other civil penalties. Given these hefty fines, we strongly encourage boards of condos and coops to comply with the requirements of LL97 or otherwise reduce their exposure if compliance is unattainable at this time.

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Authors

Leni Morrison Cummins

Chair, Condominiums & Cooperatives

lcummins@cozen.com

(212) 883-4954

Jennifer D. Miller

Member

jdmiller@cozen.com

(212) 883-4908

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