Happy 2nd Birthday to the State’s J-51 Enabling Law – and a Call to Extend the Program

October 23, 2025 marks two years since Governor Hochul signed Chapter 536 of the Laws of 2023, the state law that enabled New York City to create today’s J-51 Reform program. The bill was introduced on February 13, 2023 and ultimately became law on October 23, 2023.

What Albany Did in 2023 (and what it didn’t)

The state enacted S4709-A (Kavanagh) / A7758 (Braunstein) to amend RPTL §489 so a city over 1 million residents (i.e., NYC) could adopt a modernized tax abatement for alterations and improvements that preserve habitability in affordable housing. The state statute did not itself grant abatements; it authorized NYC to do so.

The votes

• Assembly committees: unanimous in both Ways & Means (33-0 on June 9, 2023) and Rules (25-0 on June 10, 2023).
• Senate committee: the bill advanced from Senate Rules on June 9, 2023 by a vote of 16-5.
• It then passed the Senate 40-22 that day, and passed the Assembly 136-0 the next.
• It was delivered to the Governor on October 13, 2023, and she signed it 10 days later.

From Enabling Law to NYC Program

Armed with Chapter 536, the City enacted Local Law 122 of 2024, codified at NYC Administrative Code §11-243.2. Local Law 122 took effect on December 30, 2024 – over 14 months after the state law. HPD subsequently adopted final rules in 2025 to administer the program, and named it the J-51 Reform Program.

Eligibility window (completion dates): J-51R benefits are available for projects completed after June 29, 2022 and before June 30, 2026. That means the City’s law applied retroactively to post-June 29, 2022 completions once it took effect in late 2024.

Key planning fact: There was a program gap after the prior J-51 expired on June 29, 2022 until the new program’s effective date on December 30, 2024 – about 30 months with no active benefit.

The Clock Is Ticking: Current Deadline

As written today, construction must be completed before June 30, 2026 to qualify under J-51R. For many façade, roof, elevator, and energy-efficiency projects, that’s tight – especially those starting soon who must wait 30 days after notifying tenants before commencing work. Furthermore, since outdoor projects like façade and roof are often slowed by the upcoming cold and snowy winter, these projects are less likely to be completed in time to be eligible for J-51.

What Happened in 2025  –  and What Should Happen Next

On May 16, 2025, Senator Kavanagh introduced S8170 to extend the J-51 completion deadline four years (to 2030). The Senate passed it 55-4 on June 11, 2025, but it never reached a vote in the Assembly. (Bloomberg Tax)

Our ask for 2026 and beyond: The Legislature should revisit J-51 soon, and amend both the Real Property Tax Law (§489) and the NYC Administrative Code (§11-243.2). If Albany extends only the state statute, we could still face a lag while City Council acts. A dual amendment permits immediate alignment – similar to how other NYC tax programs (i.e. ICAP recently) have been extended. We also call on the Legislature to extend J-51 in advance (also like ICAP), prior to the June 30, 2026 deadline passing – which is preferable to a retroactive implementation after long downtime, like how it was done previously.

We found this online petition where you can show your support for an extender bill: Extend J-51 through 2030: Help co-ops pay for green building upgrades! – Action Network

Why an extender matters now

• Project planning: Owners need certainty to scope, bid, finance, and sequence capital work.
• Avoiding another gap: The 2022-2024 lapse showed how uncertainty defers maintenance and upgrades.
• Policy intent: The program ties real capital investment to property tax relief, which is central to preserving the City’s aging multifamily stock.

Bottom line

Today’s two-year anniversary of the state enabling law is worth noting – it made the City’s J-51 Reform possible. But with the June 30, 2026 completion deadline approaching, Albany should pass a clean extender that updates both the RPTL and the NYC Administrative Code so the program continues without interruption and buildings can plan – and start – work with confidence.