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I am a property manager with 3 high-rise office buildings that are new to my portfolio. There are over 200 violations among the 3 buildings. In particular, I am seeing many sprinkler violations with regards to Local Law 26 of 04. In some cases, we have already upgraded the sprinklers, in others we have not. Is there a way to stop the penalties while we are making upgrades?

Final sprinkler reports under LL26/04 were due July 1, 2019. Unfortunately, DOB isn’t giving any additional time to comply.

There is a chance your building may qualify to challenge the penalty, or request a full/partial waiver, if you meet any of the criteria listed below.

For Waivers

Under 1RCNY103-11, requests must be made in writing, and must meet the following requirements:

  • A new owner requesting a waiver due to change in ownership must submit proof of a recorded deed that shows transfer of ownership to the current owner after penalties were incurred., along with any other requested documentations. This will only happen in one of the following circumstances:
    • The property was previously owned by a government entity, in which case there must be a document from the government entity affirming that it owned the property in its entirety at the time the penalties occurred.
    • The new owner received the notice of violation for a penalty that occurred before the transfer, in which case the new owner must submit a recorded deed with the date that the property was transferred. The waiver period shall extend from the date of deed transfer to the date of the violation issuance.
  • An owner may be granted a waiver if they present proof of bankruptcy signed by a court judge.
  • An owner may be granted a waiver if a state of emergency is declared that prevents an owner from conducting an inspection or filing a report.

To Challenge

If you think your building is actually in compliance or does not fall under LL26/04, you can submit proof to

However, if the buildings don’t qualify for either of these, you’ll have to pay the accrued penalty fees that recently went into effect as of January 1, 2022: Owners who fail to file a report will be fined $5,000 a year, with an additional $1,000 per month starting February 1, 2022.

For a more detailed assessment, reach out to Renee Sosnowski at


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