STATE SPECIFIC NY; CITY SPECIFIC Rochester (Sorry LONG)

Rochester Landlords: 2026 C of O and Lead Paint Changes Update

If you own rental property in the City of Rochester, you may have received an official notice in the mail around March 31, 2026, or you may be hearing about these changes for the first time. Either way, here's what you actually need to know: these changes don't affect every landlord. They apply to a specific subset of properties, and if you're in scope, you have until October 1, 2026 to come into compliance.

Here's a plain English breakdown.

First: Does This Even Apply to You?

Before anything else, run your property through this three-part test. The new requirements only apply to properties that meet ALL of the following criteria:

Built before 1980 (note: NYS Public Health Law 1377 is more stringent than the federal standard of 1978)

Located inside the City's Lead Paint High-Risk Area

Have at least 1 residential rental unit

If your property doesn't meet all three criteria, you are not subject to these changes. You can search and view impacted rental properties using the City's interactive map.

If you're unsure whether you're in the High-Risk Area, check now and don't assume.

What's Driving These Changes?

New York State passed Public Health Law 1377 (PHL 1377), which went into effect November 3, 2025. It established a statewide rental registry and new inspection and repair requirements for rental properties in areas with elevated lead poisoning risk. Monroe County Department of Public Health has delegated enforcement authority to the City of Rochester, so the City has incorporated PHL 1377 into its existing renewable Certificate of Occupancy (C of O) program.

The practical result: your C of O will now also serve as your Lead Safety Certificate under PHL 1377. You're not dealing with two separate programs; they've been merged into one process.

Rochester actually pioneered local lead paint inspection law back in 2006, so for properties with 3 or more units, much of this was already standard practice. The biggest real-world impact falls on owners of 1 and 2-unit rentals, who will now be inspected twice as frequently as before.

What Applies to All Impacted Properties

There are two requirements that apply across the board to all properties meeting the three criteria above:

All impacted properties must have an active C of O in place by 10/1/2026, or they will be subject to additional enforcement measures.

Your Building Owner Registry (BOR) submission will now double as your Rental Registry submission required by PHL 1377, and will be included in a public NYS database. Make sure your owner and property manager contact information is current at the city's registry.

What's Required By Property Type

Two-Unit Properties: Owner-Occupied or Immediate Family Occupied

This is a notable change for owner-occupants. Two-unit properties occupied by the owner or the owner's immediate family are no longer eligible for a full exemption or waiver from the City's renewable C of O requirements.

What is still exempt: the interior of the specific unit occupied by the owner or immediate family member. All other units, shared spaces, and the exterior of the property must be inspected.

Your action items:

Apply for and complete the C of O renewal process.

Any violations identified at the initial inspection must be confirmed and resolved via reinspection before a C of O will be issued.

1 and 2-Unit Rentals (Non-Owner-Occupied)

This is where the most significant change lands. These properties must now complete a C of O inspection every 3 years. Previously, the cycle was every 6 years.

Additionally, your property must have an active C of O issued on or after 10/1/2023. If it doesn't, you're required to start the renewal process now.

Your action items:

Look up your C of O issue date on the City's BuildingBlocks portal.

If your C of O predates 10/1/2023, apply for renewal immediately and don't wait for your notice.

Violations found at the initial inspection must be resolved and confirmed via reinspection before a new C of O is issued. Build that timeline into your planning.

Update your Building Owner Registry contact information here.

3-5 Unit Rentals

No changes to the inspection cycle here. 3-5 unit properties have been on a 3-year C of O cycle, and that remains the same.

The one action item: confirm your property has an active C of O issued on or after 10/1/2023. If not, apply for renewal.

6+ Unit Rentals

For larger properties, the change is the addition of proactive lead dust wipe collection for every unit. Previously, dust wipes were only conducted when deteriorated paint was found during inspection. Now they're required regardless.

For 6+ unit properties with a current C of O issued on or after 10/1/2023, the City will open a new case and require each unit to be inspected. That inspection will be limited to a visual assessment for deteriorated paint and collection of dust wipe samples. If lead hazards are identified, they must be addressed to achieve compliance.

Your action items:

Audit your C of O status across your portfolio.

Assume every unit will go through the dust wipe process and budget accordingly.

Ensure any contractors performing lead hazard work are EPA RRP certified.

The October 1, 2026 Deadline Is Real

The City has been clear: all impacted properties must have an active C of O in place by October 1, 2026, or face additional enforcement measures. Given inspection scheduling timelines, reinspection requirements, and the volume of properties involved, waiting until summer to start this process is a real risk.

Ray - most likely the "inner" city where the older properties are, multi's, etc.

I think most of the city's that have these kind of properties are going to enact this and think "oh, NY will come help with money for the people that own these" only to find out that it's not going to come and it's going to stop all repairs.

Lead paint is a serious issue especially if peeling.

I urge you all to watch season 11, episode 4 of "Forensic Files" titled "Sunday's Wake"...a very sad story of a landlord who tried to cover up a lead paint death.