Local Law 69 - Bed Bug Filing

Every December 1 through December 31, many NYC condos and co-ops must file a bed bug report with HPD.

For small self-managed boards, that is the key takeaway. This is an annual city filing with a fixed deadline, and it can be easy to overlook if nobody on the board is specifically responsible for compliance.

The report covers the prior reporting period of November through October, and even buildings with no bed bug infestations may still need to file. Questions about exactly who qualifies can come next, but the first thing board members should know is simple: bed bug filing season happens every December.

What is Local Law 69?

Local Law 69 of 2017 requires owners of certain multiple dwellings in New York City to attempt to collect bed bug infestation history for units in the building and file an annual report with HPD.

For small condo and co-op boards, this should be treated as a recurring compliance item, not a one-time task.

Does this apply to all condos and co-ops?

Not necessarily, but many small buildings should assume this is something they need to check every year.

In general, the requirement is tied to multiple dwellings and HPD registration requirements. Many residential buildings with 3 or more units fall into that broader framework. That is why small condo and co-op boards should not ignore this just because the building is small or mostly owner-occupied.

A practical rule of thumb is:

• If your building has 3 or more residential units, check whether the filing applies.
• Do not assume that having no infestations means there is nothing to file.

What information does the board need?

The board, owner, or managing agent generally needs to gather bed bug history for the reporting period.

For a small building, that usually means asking each unit whether there was a bed bug infestation during the reporting period and whether steps were taken to address it. Even if the process is straightforward, it helps to have a repeatable system each fall so the filing does not become a last-minute scramble in December.

When is the filing due?

The annual filing window is December 1 through December 31.

The report covers November of the previous year through October of the current year. If the filing is missed, the building may face compliance issues or violations.

For volunteer board members, the challenge is usually not complexity. It is timing. December is busy, and this is exactly the kind of deadline that can slip through the cracks. Just as importantly, do not file early — the report must be filed within the filing window.

How do you file?

The filing is generally made through HPD, and the building’s property registration typically needs to be current before the report can be submitted.

For small condo and co-op boards, the main point is less about the mechanics and more about ownership: someone should be responsible for making sure the building is registered, the filing is submitted during the proper window, and the confirmation is retained in the building’s records.

Why this matters

For small self-managed buildings, the real risk is often not the bed bug issue itself. It is missing a city filing requirement because no one realized it was due.

That is why this is worth simplifying:

• The filing window is every December 1 through December 31
• Many small condos and co-ops may be subject to it
• It should be treated as a recurring annual compliance task

Bottom line

Every December 1 through December 31, many NYC condos and co-ops must file a bed bug report with HPD.Even if your building is small, it is worth checking whether the requirement applies and making sure someone owns the process each year.

For self-managed boards, the best approach is simple: put it on the calendar, gather unit information in the fall, confirm registration, and file on time.