This September and October 2025, the New York City Department of Buildings is issuing coordinated enforcement actions across two critical safety programs: gas piping inspections and elevator compliance. Building owners throughout NYC are receiving Notices of Deficiency for missed gas piping certifications and violations for elevator non-compliance from the 2024 cycle.
Understanding these enforcement actions and responding appropriately can help you avoid escalating penalties and operational disruptions.
Gas Piping NODs: Cycle 1 Non-Compliance
What Are Gas Piping Inspections?
Local Law 152 requires most NYC buildings with gas service to complete periodic gas piping system inspections every four years. Buildings subject to inspection include multi-family residential (3+ units), commercial, mixed-use, and institutional properties. One- and two-family homes (Occupancy Group R-3) are exempt.
Gas piping inspections follow a four-year cycle divided into sub-cycles based on Manhattan Community District:
- Sub-cycle A: CDs 1, 3, 10 | Cycle 2: Jan 1 – Dec 31, 2024
- Sub-cycle B: CDs 2, 5, 7, 13, 18 | Cycle 2: Jan 1 – Dec 31, 2025
- Sub-cycle C: CDs 4, 6, 8, 9, 16 | Cycle 2: Jan 1 – Dec 31, 2026
- Sub-cycle D: CDs 11, 12, 14, 15, 17 | Cycle 2: Jan 1 – Dec 31, 2027
What Is a Notice of Deficiency?
A Notice of Deficiency (NOD) is a formal warning that appears on your property’s public record but carries no immediate financial penalty. It’s the DOB’s final warning before issuing violations with substantial fines.
Who Is Receiving Gas Piping NODs?
The DOB is issuing NODs to Sub-cycles B and C building owners who failed to submit Gas Piping System Periodic Inspection Certifications (GPS2) during Cycle 1:
- Sub-cycle B: Failed to file during Jan 1, 2021 – Jun 30, 2022 | Must comply by Dec 31, 2025
- Sub-cycle C: Failed to file during Jan 1, 2022 – Dec 31, 2022 | Must comply by Dec 31, 2026
Critical for Sub-cycle B buildings: Only months remain to schedule inspections, complete any required repairs, and file GPS2 certifications before the December 2025 deadline.
How to Respond to Gas Piping NODs
Achieve Cycle 2 Compliance:
Hire a licensed Master Plumber to inspect your gas piping system, address any deficiencies, and submit the GPS2 certification by your cycle deadline. Once filed, your NOD will be dismissed.
Submit a Challenge Request:
If your building is exempt, doesn’t have gas service, or you did file during Cycle 1, you can challenge the NOD within 30 days through DOB NOW.
Consequences of Ignoring NODs:
Failure to achieve Cycle 2 compliance will result in violations with civil penalties of $1,500 (3-family residential) or $5,000 (all other buildings), plus escalating enforcement for continued non-compliance.
Elevator Violations: 2024 Cycle Non-Compliance
NYC Elevator Inspection Requirements
NYC requires multiple elevator inspection types to ensure safe operation:
- Category 1 (CAT 1) Tests: Annual safety examinations of braking systems, governors, door interlocks, and safety equipment. Due December 31 annually.
- Category 5 (CAT 5) Tests: Performed within 5 years from the month of the most recent CAT5 test, or with rated load and speed every 5 years from the month of issuance of a Certificate of Compliance for a new elevator.
- Periodic Inspections: Comprehensive assessments performed every 1-5 years depending on elevator type. Due December 31 in required years.
What Elevator Violations Are Being Issued?
The DOB is issuing violations for three types of 2024 non-compliance:
- Failure to file CAT 1 test reports for 2024
- Failure to file periodic inspection reports for 2024
- Failure to file affirmations of correction for 2024 defects
Initial penalties range from $2,500 to $5,000 and continue accruing monthly until resolved.
How to Address Elevator Violations
Building owners have several response options through DOB NOW: Safety:
Pay the Violation:
Direct payment resolves the violation but doesn’t address ongoing compliance requirements. Appropriate when the violation is valid and you’ll immediately achieve current compliance.
Request a Civil Penalty Waiver:
Apply for waivers under specific circumstances. Requires $35 application fee and supporting documentation. If granted, the violation is dismissed, but compliance obligations remain.
Challenge the Violation:
If the violation was issued in error (inspection was completed but not properly recorded), submit a challenge through DOB NOW with supporting evidence.
Critical Note: Resolving 2024 violations doesn’t eliminate your 2025 obligations. Buildings must schedule CAT 1 tests and periodic inspections immediately to meet the December 31, 2025 deadline—and Q4 inspection capacity is severely constrained.
Moving from Enforcement to Proactive Compliance
Both gas piping NODs and elevator violations stem from missed compliance deadlines and inadequate tracking systems. The DOB’s coordinated fall 2025 enforcement demonstrates its systematic approach to building safety across NYC.
Properties facing enforcement now must address two challenges simultaneously:
- Resolve current NODs and violations through payments, waivers, or challenges
- Achieve current-cycle compliance before new deadlines pass
Buildings that successfully transition from reactive to proactive compliance share key practices: centralized deadline tracking across all building systems, early scheduling at the beginning of compliance periods, organized documentation of inspections and certifications, and established relationships with qualified contractors.
Comprehensive Compliance Management and Violation Remediation
Prise helps NYC property managers stay ahead of gas piping inspections, elevator requirements, and all building compliance deadlines through centralized tracking, automated deadline reminders, and comprehensive documentation management.
Beyond compliance tracking, Prise offers full violation remediation services. Our team schedules and attends DOB hearings on your behalf, working directly with city agencies to clean your record, negotiate reduced fines, or establish practical compliance agreements. You manage your properties while we navigate DOB bureaucracy for you.
Contact us today to learn how Prise prevents enforcement actions and resolves existing violations.
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