Façade files: Your guide to FISP Cycle 10A compliance - by Dom Diaz
NYC’s Façade Inspection & Safety Program (FISP), formerly known as Local Law 11, is one of the most rigorous building façade safety initiatives in the country. Administered by the NYC Department of Buildings (DOB), the program mandates that owners of buildings taller than six stories have their exterior walls and appurtenances inspected at prescribed intervals and submit a technical report prepared by a Qualified Exterior Wall Inspector (QEWI). As we move into 2025-Cycle 10A, which began on February 21, 2025, marks a critical milestone for thousands of building owners across the city. Understanding what’s required – and when – is essential to ensure compliance, minimize costly penalties, and most importantly, maintain the safety of residents, pedestrians, and the public.
What Is FISP and Why Does It Matter? FISP was enacted to ensure that NYC’s dense urban environment remains safe from falling building material and structural hazards stemming from deteriorating building façades. Since its inception in 1980 (as Local Law 10) and the subsequent expansion into Local Law 11 in 1998, the scope of inspections has grown considerably.
Under FISP, every building over six stories must have its façades inspected and a report filed once every five years. Façades fronting public ways (streets, plaza, etc.) must have their façade inspected with close-up inspection from a hanging scaffolding every 60’-0”. The city divides this process into cycles (we are entering Cycle 10) and sub-cycles (A, B, and C), based on the last digit of the building’s block number. Failing to file on time – or worse, filing after an incident has occurred – can result in significant fines and legal liability.
When Is My Report
Due Under Cycle 10?
For Cycle 10, the filing windows are as follows:
• Sub-cycle 10A: Buildings with a block number ending in 4, 5, 6, or 9
Filing Window: February 21, 2025 – February 21, 2027
• Sub-cycle 10B: Buildings with a block number ending in 0, 7, or 8
Filing Window: February 21, 2026 – February 21, 2028
• Sub-cycle 10C: Buildings with a block number ending in 1, 2, or 3
Filing Window: February 21, 2027 – February 21, 2029
If your building falls into Cycle 10A, you are expected to complete your inspection and file your report between February 21, 2025 and February 21, 2027.
Considerations and Requirements in Cycle 10: While the core principles of FISP have remained the same, Cycle 10 comes with some important updates and clarifications building owners should be aware of:
1. Drone Usage: While drones are still not permitted for official inspection filing purposes, DOB is increasingly allowing drone imagery as a supplementary tool during preliminary and supplement assessments. Drones are not to replace close-up inspections from hanging scaffolding.
2. Unsafe Reports and Amended Reports: If Unsafe conditions are observed, the building must install safety protection and remediate the condition. Once the Unsafe condition is corrected, an Amended Report can be submitted, confirming remediation of the condition. Timing and documentation are key to avoid enforcement penalties.
3. Increased Emphasis on Public Protection: Buildings classified as “Unsafe” must immediately install pedestrian protection (e.g., sidewalk sheds) and submit a repair plan. These protections must remain in place until the condition is addressed and reclassified as Safe or Safe with a Repair and Maintenance Program (SWARMP).
4. More Detailed Reports: DOB expects increasingly thorough documentation, including photographic evidence, detail methodology on the process to evaluate a condition, elevation drawings with defect locations, and detailed repair scopes. QEWI involvement is critical from the outset.
Understanding FISP
Classifications
Each FISP report must classify the building as one of the following:
• Safe: No problems, and no foreseeable issues in the next five years.
• SWARMP (Safe with a Repair and Maintenance Program): Minor issues that are not immediately hazardous but must be corrected before the next cycle. Many of these conditions can have “cure” dates that require repair prior to the next cycle.
• Unsafe: Conditions that pose an immediate risk to public safety. Repairs must begin immediately with protection of the public.
Knowing your classification helps guide your planning and budget. Owners should not assume “SWARMP” means they can delay repairs indefinitely – unaddressed SWARMP conditions can quickly deteriorate and downgrade to “Unsafe”, if not corrected prior to the “cure” date.
The Cost of Non-Compliance: Missing your filing window or failing to correct unsafe conditions comes with substantial consequences. Some penalties include:
• Failure to file: $5,000 annually until a report is submitted;
• Monthly late filings: Additional $1,000; and
• Unsafe conditions not addressed: Daily fines and potential DOB violations.
Beyond monetary penalties, non-compliance can hinder insurance coverage, impede refinancing efforts, and in severe cases, trigger litigation if injuries occur due to façade neglect.
What Should Building
Owners Do Now?
If your property falls within Cycle 10A, early planning is essential. Consider taking the following steps:
1. Engage a QEWI Early: Don’t wait until the deadline is looming. A qualified architect or engineer can perform a preliminary assessment and outline a realistic timeline for the full inspection and report filing.
2. Review Past Reports: If your building had SWARMP conditions in Cycle 9, ensure those repairs are documented and completed.
3. Budget for Repairs: Most façade issues require scaffolding, sidewalk bridging, permits, and contractor coordination. The earlier you start, the more flexibility you’ll have with scheduling and costs. Material replacement may require long fabrication times as well.
4. Maintain Documentation: Keep detailed records of repairs, inspections, and permits. This helps streamline the filing process and protects you in the event of DOB inquiries.
Final Thoughts: FISP compliance may seem like a bureaucratic hurdle, but it plays a vital role in maintaining the safety and longevity of New York City’s architecture. For building owners, the key is proactive engagement – delaying inspections or filing under pressure often leads to higher costs and unnecessary stress.
As Cycle 10A approaches, take the opportunity to understand your responsibilities, build your team, and make informed decisions that support both public safety and the long-term value of your property.
Dom Diaz, RA is president at Diaz Architects, New York, N.Y.