Article 7 Filing Season: File by October 24, 2025 to preserve your 2025/26 NYC property tax challenge

It’s that time again. If you (or another party with standing) filed a Tax Commission application for the 2025/26 tax year and did not settle at the Tax Commission, you can and should preserve your rights by filing an Article 7 tax certiorari petition in the Supreme Court of the county where the property is located (New York, Kings, Queens, Bronx, or Richmond) no later than Friday, October 24, 2025.

Who should file this year?

You generally have a petition to file for 2025/26 (July 1, 2025 – June 30, 2026) if you timely filed a Tax Commission application (by the March 2025 deadline) and you did not settle for any of the following common reasons:

• No hearing this year (you passed or weren’t eligible – often because a required income & expense filing such as TC201 wasn’t submitted, or you were RPIE non‑compliant). The Tax Commission’s 2024 report shows that non‑eligibility and missing filings (RPIE/TCIE), late/incomplete applications, and non‑appearance are routine reasons cases don’t get heard..
• Hearing hasn’t occurred yet (2025 hearings are scheduled to run through December 2025, so many applications will still be pending by the October 24^th filing deadline).
• Hearing held but determination still pending (Tax Commission determinations typically follow one to two months after the hearing).
• Hearing held and the Tax Commission confirmed the assessment (no offer).
• Offer made but not accepted (sometimes deliberate where the offer wasn’t strong enough and the owner wants to try again next year – remember, the Tax Commission can, in certain circumstances, review more than one year when a valid prior‑year Article 7 is pending). The Annual Report explains that proper filing of an Article 7 petition is a prerequisite to Tax Commission review of a prior year’s assessment and that, in unusual cases, the Commission may review earlier years within the last five – provided a valid court proceeding is pending.

Important interplay with Tax Commission offers: If you accept a Tax Commission offer for the current year, you must agree not to file an Article 7 for that year and to discontinue any pending prior‑year court proceedings. If you intend to keep the option to litigate the current year open, you must file the petition by October 24; you can always discontinue later if you reach a settlement you’re satisfied with.

E‑filing mechanics this year (NYSCEF + the 2025 stipulation)

For 2025/26 cases, the City and petitioners have again consented to e‑filing in all NYC counties under a uniform stipulation. Highlights:

• Deadline: Petitions must be e‑filed and index numbers purchased before October 25, 2025 – which functionally means by October 24, 2025 (the courts will not accept a petition uploaded after that deadline).
• What counts as service: Proper service of an e‑filed petition on the City is deemed made when NYSCEF transmits the “Receipt of Filing and Payment for Tax Certiorari Cases.” Keep that receipt; provide it to the City upon request.
• Data Upload Method: You may file in bulk via NYSCEF’s Tax Cert Data Upload. If you don’t use that method (e.g., you “Start a New Case”), you must provide the Tax Commission with a data file or printout of petition information by Monday, October 27, 2025 in the specified format.
• Other papers: RJIs, Notes of Issue, and discontinuance stipulations can be e‑filed; other documents may also be e‑filed but must still be served in hard copy on the City.
• Condominiums: Condo petitions can be e‑filed so long as no more than eight ranges of lots within one condominium (same block) are included.

What an Article 7 petition actually claims

Although most taxpayers file because they believe the property is over‑assessed (assessed value too high), the standard form petition is a “kitchen‑sink” pleading. It typically alleges excessiveness (overvaluation), inequality, unlawfulness, misclassification, issues with transitional assessments, and other statutory claims (for example, claims under RPTL § 581 for co‑ops/condos or exemption‑related statutes when applicable).

Why this matters for taxes: NYC sets taxes by multiplying assessed value (after exemptions) by the tax rate. Because assessed value is derived as a percentage of market value (the current target assessment ratios are 6% for tax class 1 and 45% for tax classes 2, 3, and 4, subject to applicable limits), correcting an over‑assessment directly affects the tax bill.

A quick look at last season’s volume (to set expectations)

The Tax Commission’s 2024 report shows the scale of the process citywide:

• 57,304 applications covering 261,272 lots were filed for 2024/25, covering $274.1 billion of collective assessments at issue;
• 8,045 offers (covering 43,935 lots) were given in 2024;
• 49,259 applications (217,337 lots) received no offers in 2024;
• 2,686 applications received remedial offers in 2024 to reduce 2023 assessments, covering $19.26 billion of collective assessments at issue.

These numbers help explain why many 2025/26 applications will still be unresolved when the Article 7 deadline arrives – another reason to file now to preserve rights.

Practical checklist: filing to preserve your 2025/26 challenge

1. Confirm standing (owner or other party with a sufficient interest, such as a net lessee paying the taxes).
2. Confirm timely Tax Commission application for 2025/26.
3. Decide on e‑filing approach (NYSCEF Data Upload vs. individual filings). If not using Data Upload, calendar the Oct. 27 data‑submission requirement.
4. Prepare the petition (include all appropriate claims – even if the core issue is over‑assessment).
5. File in the correct county Supreme Court and purchase an index number for each petition by Oct. 24. The cost is $210, but with the credit card processing fee, the total is $216.28.
6. Verify service via the NYSCEF Receipt of Filing and Payment email; retain it.
7. Keep negotiating at the Tax Commission/Law Department. If you accept a Tax Commission offer later, you will stipulate to discontinue the pending Article 7 – and you cannot maintain a current‑year Article 7 after accepting.

A note for small homes

Owner‑occupied one‑ to three‑family homes (generally tax class 1) may be eligible for Small Claims Assessment Review (SCAR) as an alternative to Article 7. The Tax Commission’s notice of determination explains how to initiate SCAR.

Conclusion

If your 2025/26 case didn’t resolve at the Tax Commission – or won’t be heard in time – file the Article 7 petition by October 24, 2025 to keep the year open. You can always discontinue later if a settlement makes sense, but you cannot reopen the year if you miss the deadline. For a refresher on the basics, last year’s explainer remains a helpful primer: https://www.rosenbergestis.com/media/blog/nyc-property-tax/article-7-petitions-to-protest-nyc-property-taxes.

This post is for general information only and isn’t legal advice for any specific property or situation.