What buildings need FISP or Local Law 11?

Under NYC Construction Codes §28-302.1, owners of buildings greater than six stories must keep exterior walls and appurtenances in a safe condition, have them inspected on a five-year cycle, and file a technical façade report. 1 RCNY §103-04 says the rule applies to buildings with exterior walls or parts of walls greater than six stories, regardless of what the Certificate of Occupancy says. A building with six stories above grade plane plus a cellar can also be in the program if more than half the height of that cellar, measured at any individual exterior wall, is above adjacent ground. DOB publishes a FISP Universe Map, and it is still the owner's job to confirm whether the building is subject to the program.

How do Cycle 10 filing windows work?

Reports are due at least once in each five-year filing cycle. Inside the cycle, DOB uses two-year filing windows so every building does not hit the same QEWI calendar on the same day. Your window is set by the last digit of the building's block number, not the lot, and not the street address. DOB's February 24, 2025 Cycle 10 service notice sets Sub-cycle A (block ending in 4, 5, 6, or 9) from February 21, 2025 through February 21, 2027, Sub-cycle B (block ending in 0, 7, or 8) from February 21, 2026 through February 21, 2028, and Sub-cycle C (block ending in 1, 2, or 3) from February 21, 2027 through February 21, 2029. An acceptable report has to be filed inside that two-year window to avoid a late-filing penalty.

What do Safe, SWARMP, and Unsafe mean for insurance?

After the critical examination, the QEWI classifies the building as Safe, Safe With a Repair and Maintenance Program (SWARMP), or Unsafe. Safe means the walls and appurtenances do not need repair or maintenance to stay structurally sound, and they will not become unsafe during the next five years. SWARMP means the condition is safe at inspection, but it needs repair or maintenance during the next five years, and not less than one year, so it does not become unsafe. The same condition may not be filed as SWARMP for two consecutive cycles. If it was SWARMP last cycle and it is still not corrected, it is Unsafe this cycle. Unsafe means the condition is hazardous to persons or property and requires repair within one year of completing the critical examinations. Unsafe is where the sidewalk and the insurance program change in public: the owner must immediately take action to protect the public, and 1 RCNY §103-04 names sidewalk sheds, fences, and safety netting among the measures used. FISP forces work, access equipment, and contractors onto a New York building, and that is what underwriters price.

NYC Local Law 11 Facade Cycles: What FISP Means for Insurance and When to Call Your Broker

Owners hear Local Law 11 and think of a Department of Buildings (DOB) filing. Boards hear the Façade Inspection and Safety Program (FISP) and think of a Qualified Exterior Wall Inspector (QEWI) on a scaffold drop. Both are right, and both miss the part that hits the insurance program. The moment the report is Unsafe or SWARMP, you are not only in a compliance cycle. You are about to put contractors, sidewalk sheds, and height work on a building that already carries New York sidewalk and gravity-related liability.

This is not a substitute for a QEWI or building counsel. It is the insurance conversation we have with multifamily owners, investors, boards, and managing agents before Cycle 10 work starts, not after a carrier or a lender asks why the sidewalk is in a shed.

If you want that review on a specific building, email us at team@serheydavidson.com with the address, unit count, current declarations, and your latest FISP status if you have it.

Local Law 11 and FISP are the same program, in DOB language

People still say Local Law 11. The Department of Buildings administers the work as the Façade Inspection and Safety Program, or FISP. DOB's own filing-status tool is still titled Façade Filing Status - Local Law 11.

Under NYC Construction Codes §28-302.1 and DOB's façade compliance page, owners of buildings greater than six stories must keep exterior walls and appurtenances in a safe condition, have them inspected on a five-year cycle, and file a technical façade report. The inspections are called critical examinations. Only a DOB-approved Qualified Exterior Wall Inspector (QEWI) may perform them. Filings go through DOB NOW: Safety.

A QEWI is a New York State registered architect or professional engineer with at least seven years of relevant experience on façades over six stories, accepted by DOB. The examination is performed by or under that QEWI's direct supervision.

The six-story trigger is not a casual guess from the Certificate of Occupancy. 1 RCNY §103-04 says the rule applies to buildings with exterior walls or parts of walls greater than six stories, regardless of what the C of O says. There is also a cellar rule: a building with six stories above grade plane plus a cellar can be in the program if more than half the height of that cellar, measured at any individual exterior wall, is above adjacent ground. DOB also publishes a FISP Universe Map, and it is still the owner's job to confirm whether the building is subject to the program.

If you are not sure you are in, do not wait for a violation to find out. Confirm with your QEWI and the DOB records, then loop the broker in before you schedule drops.

Cycle 10 is staggered by the last digit of the tax block

Reports are due at least once in each five-year filing cycle. Inside the cycle, DOB uses two-year filing windows so every building does not hit the same QEWI calendar on the same day. Your window is set by the last digit of the building's block number, not the lot, and not the street address.

DOB's February 24, 2025 Cycle 10 service notice sets these windows for buildings taller than six stories:

Sub-cycle A: block ending in 4, 5, 6, or 9. Filing window February 21, 2025 through February 21, 2027.
Sub-cycle B: block ending in 0, 7, or 8. Filing window February 21, 2026 through February 21, 2028.
Sub-cycle C: block ending in 1, 2, or 3. Filing window February 21, 2027 through February 21, 2029.

An acceptable report has to be filed inside that two-year window to avoid a late-filing penalty. The QEWI must also file within 60 days of completing the critical examination. Miss that 60-day clock and the rule requires a new critical examination. The report also may not be filed more than one year after the close-up inspection is completed.

If you have a portfolio, pull block digits now. Two buildings on the same management calendar can sit in different sub-cycles.

Safe, SWARMP, and Unsafe are insurance events, not just labels

After the critical examination, the QEWI classifies the building as Safe, Safe With a Repair and Maintenance Program (SWARMP), or Unsafe.

Safe means the walls and appurtenances do not need repair or maintenance to stay structurally sound, and they will not become unsafe during the next five years.
SWARMP means the condition is safe at inspection, but it needs repair or maintenance during the next five years, and not less than one year, so it does not become unsafe. The same condition may not be filed as SWARMP for two consecutive cycles. If it was SWARMP last cycle and it is still not corrected, it is Unsafe this cycle.
Unsafe means the condition is hazardous to persons or property and requires repair within one year of completing the critical examinations.

Unsafe is where the sidewalk and the insurance program change in public. The owner must immediately take action to protect the public. 1 RCNY §103-04 names sidewalk sheds, fences, and safety netting among the measures used. The repair clock is 90 days from filing the unsafe report, unless the QEWI gets an acceptable time extension.

DOB's published filing fees are $425 for an initial filing, $425 for an amended or subsequent filing, $305 for an extension of time to complete repairs, and $140 to request a waiver of penalties. After the filing period ends, late filing of the initial report is $1,000 per month, and failure to file is $5,000 per year. Those are DOB civil amounts. They are not a quote for your premium.

The QEWI drop is not the insurance inspection

FISP is the DOB critical examination. The carrier inspection is loss control after you bind or renew. They are not the same person, the same form, or the same deadline. See also: Understanding Insurance Inspection Recommendations.

What actually changes in the insurance program

FISP forces work, access equipment, and contractors onto a New York building. That is what underwriters price.

General liability and the sidewalk: a shed sits in the public way. See sidewalk liability for NYC multi-family owners.

Labor Law 240 and 241: facade repair is height work. See NYC contractor insurance guide and owners and contractors protective insurance in NYC.

Certificates, builders risk, and open facade violations as underwriting all need a look before the first drop. Building-owner program: building owners insurance NYC.

When to talk to the broker

Talk before you confirm FISP status, retain a QEWI, get a SWARMP or Unsafe report, put up a shed, sign a restoration contract, answer a carrier loss-control list, buy or refinance a building with NRF or Unsafe history, or renew inside an active filing window.

What to send Us

Address, entity, unit count, occupancy, current declarations, latest FISP classification if you have it, whether a shed is up, contractor COIs, and any open carrier recommendations. Email team@serheydavidson.com or call 212-964-7802.

Frequently Asked Questions

Is Local Law 11 the same as FISP?: Yes. People still say Local Law 11. The Department of Buildings administers the work as the Façade Inspection and Safety Program, or FISP. DOB's own filing-status tool is still titled Façade Filing Status - Local Law 11.
What buildings need FISP or Local Law 11?: Under NYC Construction Codes §28-302.1, owners of buildings greater than six stories must keep exterior walls and appurtenances in a safe condition, have them inspected on a five-year cycle, and file a technical façade report. 1 RCNY §103-04 says the rule applies to buildings with exterior walls or parts of walls greater than six stories, regardless of what the Certificate of Occupancy says. A building with six stories above grade plane plus a cellar can also be in the program if more than half the height of that cellar, measured at any individual exterior wall, is above adjacent ground. DOB publishes a FISP Universe Map, and it is still the owner's job to confirm whether the building is subject to the program.
How do Cycle 10 filing windows work?: Reports are due at least once in each five-year filing cycle. Inside the cycle, DOB uses two-year filing windows so every building does not hit the same QEWI calendar on the same day. Your window is set by the last digit of the building's block number, not the lot, and not the street address. DOB's February 24, 2025 Cycle 10 service notice sets Sub-cycle A (block ending in 4, 5, 6, or 9) from February 21, 2025 through February 21, 2027, Sub-cycle B (block ending in 0, 7, or 8) from February 21, 2026 through February 21, 2028, and Sub-cycle C (block ending in 1, 2, or 3) from February 21, 2027 through February 21, 2029. An acceptable report has to be filed inside that two-year window to avoid a late-filing penalty.
What do Safe, SWARMP, and Unsafe mean for insurance?: After the critical examination, the QEWI classifies the building as Safe, Safe With a Repair and Maintenance Program (SWARMP), or Unsafe. Safe means the walls and appurtenances do not need repair or maintenance to stay structurally sound, and they will not become unsafe during the next five years. SWARMP means the condition is safe at inspection, but it needs repair or maintenance during the next five years, and not less than one year, so it does not become unsafe. The same condition may not be filed as SWARMP for two consecutive cycles. If it was SWARMP last cycle and it is still not corrected, it is Unsafe this cycle. Unsafe means the condition is hazardous to persons or property and requires repair within one year of completing the critical examinations. Unsafe is where the sidewalk and the insurance program change in public: the owner must immediately take action to protect the public, and 1 RCNY §103-04 names sidewalk sheds, fences, and safety netting among the measures used. FISP forces work, access equipment, and contractors onto a New York building, and that is what underwriters price.
Is the QEWI drop the same as a carrier insurance inspection?: No. FISP is the DOB critical examination. The carrier inspection is loss control after you bind or renew. They are not the same person, the same form, or the same deadline.
When should owners talk to the broker?: Talk before you confirm FISP status, retain a QEWI, get a SWARMP or Unsafe report, put up a shed, sign a restoration contract, answer a carrier loss-control list, buy or refinance a building with NRF or Unsafe history, or renew inside an active filing window.
What should owners send for a review?: Send the address, entity, unit count, occupancy, current declarations, latest FISP classification if you have it, whether a shed is up, contractor COIs, and any open carrier recommendations. Email team@serheydavidson.com or call 212-964-7802.

Not legal advice

This article is general insurance information. It is not legal advice, not a QEWI opinion, and not a determination of whether any specific building is subject to FISP.