New York City’s Local Law 23 of 2026, known as the “Cool Homes for All Act,” creates a legal right to cooling in tenant-occupied dwellings. The law applies to many small and mid-size properties across Bushwick, Bed-Stuy, East New York, Crown Heights, Ridgewood, and other NYC neighborhoods.
The requirement is phased. Tenants may begin making formal cooling elections on March 1, 2028. Full enforcement begins on June 1, 2030.
Owners do not need to install equipment in every sleeping room immediately. However, properties with older electrical systems, limited exterior-wall options, or rent-stabilized apartments need a planning process well before the first request window opens.
Why did NYC create a cooling mandate?
New York City has long regulated minimum indoor temperatures during the winter heat season. Local Law 23 adds a summer cooling framework because extreme heat creates a separate housing and public-health concern.
The law defines the cooling season as June 15 through September 15. During that period, when the outdoor temperature exceeds 82°F, a covered sleeping room must be capable of maintaining an indoor temperature of no more than 78°F.
The law also establishes technical standards for approved systems. For example, a non-central cooling system generally must have a cooling capacity of at least 20 British thermal units per hour for each square foot of floor area within the cooling area, unless the Department of Buildings establishes an alternative standard by rule.
The indoor temperature is measured under defined conditions, including at least three feet above the floor and at least three feet away from an exterior wall. Owners should therefore evaluate systems based on documented capacity and installation standards, not only on whether a unit appears to produce cold air.
The official text of Local Law 23 should remain the starting point for planning. Additional agency rules and forms will provide further details.
Which Brooklyn properties and tenants are covered?
Local Law 23 applies broadly to covered dwellings, including:
- Tenant-occupied one- and two-family homes.
- Three- and four-family properties.
- Larger multiple dwellings.
- Market-rate apartments.
- Rent-stabilized and other regulated apartments.
- Condominiums and cooperatives where the individual unit is tenant-occupied.
For a typical two-family home in Bushwick, the law can apply to the tenant-occupied unit. For a 30-unit rent-stabilized building in Bed-Stuy, it can apply to covered sleeping rooms in individual apartments after tenants make the required election.
The law focuses on covered rooms. A covered room is generally a room known, or reasonably expected, to be used as the primary sleeping place of a permanent occupant.
This does not necessarily mean that every room in every apartment must receive a separate air-conditioning unit. The owner must provide adequate cooling to each covered room that becomes subject to the requirements through the tenant election process.
Which city agencies will administer the program?
The law involves several city functions.
What will the Department of Buildings handle?
The Department of Buildings will be responsible for technical rules connected with:
- Approved cooling-system capacity.
- Building-code compliance.
- Electrical and mechanical work.
- Installation requirements.
- Permits and construction filings where required.
- Central and permanent non-central cooling systems.
DOB’s local-law materials identify Local Law 23 as a change to the Administrative Code and Building Code involving cooling systems in tenant-occupied dwellings. Owners should monitor DOB’s Local Laws page for final rules and technical guidance.
What will HPD handle?
The Department of Housing Preservation and Development is expected to serve as the primary housing-code enforcement agency for cooling complaints and hardship-extension requests. This follows the existing NYC model for habitability conditions such as heat, hot water, and other housing-maintenance requirements.
Beginning June 1, 2030, tenants will be able to use 311 to report non-compliance when the law’s requirements apply. The exact complaint categories and agency procedures may be clarified before enforcement begins.
The Department of Health and Mental Hygiene may also support public-health education, heat-risk outreach, energy-saving guidance, and tenant communications.
Because implementation rules are still developing, owners should avoid relying on informal summaries alone. A property manager should track updates from DOB, HPD, and the city’s official rules portal.
What is the timeline for owners?
The main dates are straightforward, but each one has a different practical effect.
| Date | Requirement or planning milestone |
|---|---|
| 2026 | Local Law 23 is enacted and planning begins. |
| January 1, 2028 | The city must make a tenant notice available in English and designated citywide languages. |
| March 1, 2028 | Tenants may begin electing covered sleeping rooms for cooling. |
| 60 days after an election | The cooling requirement generally takes effect for the elected covered room. |
| March 1, 2028–September 1, 2029 | Owners must provide and post the required city notice within the statutory window. |
| June 15–September 15 | Annual cooling season. |
| June 1, 2030 | Full compliance and enforcement date. |
| June 1, 2031 | Annual inspections and recordkeeping begin for covered systems subject to the request-based requirement. |
| June 1, 2032 | The city must begin publishing annual post-enforcement reports. |
A request made on March 1, 2028 could create a compliance deadline approximately 60 days later. Owners should not wait until the first request arrives to determine whether a bedroom can safely support a window unit or whether a new circuit is necessary.
What must the landlord provide, and who pays?
The owner is generally responsible for:
- Purchasing or providing the cooling equipment.
- Installing the equipment.
- Obtaining required permits or approvals.
- Maintaining the system.
- Ensuring the system remains capable of providing adequate cooling.
- Keeping required inspection and maintenance records.
The tenant is responsible for the electricity used to operate a furnished cooling unit, subject to the lease and applicable rules. Beginning March 1, 2028, leases and renewal leases must identify who pays the electricity costs for cooling systems furnished under the law.
Possible equipment strategies include:
- Window air-conditioning units.
- Through-wall units installed in permanent sleeves.
- Heat-pump systems.
- Central cooling.
- Other approved systems that meet the city’s technical requirements.
A window unit may appear less expensive, but the installation still needs to account for structural support, water drainage, fire-escape limitations, window dimensions, electrical load, and safe removal or maintenance access. The law does not require an owner to install equipment in a way that violates fire-code requirements.
How will rent-stabilized owners address rent increases?
Local Law 23 does not automatically authorize a rent increase whenever an owner installs an air-conditioning unit. For rent-stabilized apartments, owners must coordinate the cooling work with New York State housing rules and DHCR documentation requirements.
The law specifically requires a rent-regulated tenant to consent to improvements and associated charges in a manner consistent with state law before the owner’s obligation takes effect for that unit.
Depending on the project, existing DHCR pathways may include the following.
Could an apartment-level installation qualify as an IAI?
An owner-purchased and owner-installed air-conditioning system in an occupied rent-stabilized apartment may be treated as an Individual Apartment Improvement, or IAI.
Existing DHCR rules generally use:
- 1/168 of verified cost for buildings with 35 or fewer apartments.
- 1/180 of verified cost for buildings with more than 35 apartments.
For example, if a qualifying installation costs $3,360 in a 30-unit building, the initial calculation at 1/168 would be $20 per month before considering applicable rules and approvals. A $3,600 installation in a larger building would produce a preliminary calculation of $20 per month at 1/180.
These calculations are examples only. Owners should confirm the applicable rule when the work is performed.
For an occupied rent-stabilized apartment, documentation should generally include:
- Written tenant consent to the improvement and rent increase.
- A description of the equipment.
- Itemized invoices.
- Installation contracts.
- Proof of payment.
- Completion date.
- Required permit or inspection records.
- Updated rent-registration documentation where applicable.
The New York State Homes and Community Renewal guidance on apartment improvements should be reviewed before an owner presents a consent agreement.
Could a building-wide project qualify as an MCI?
A central cooling system, building-wide cooling infrastructure, or circuits and outlets installed throughout a building may be evaluated as a Major Capital Improvement, or MCI.
An MCI is not automatic. The owner must apply to DHCR and demonstrate that the project meets the applicable criteria. Supporting materials may include:
- A complete project description.
- Itemized contractor invoices.
- Contracts and proof of payment.
- Permits and sign-offs.
- Evidence that the improvement benefits the building.
- Evidence that the work is depreciable and more than an ordinary repair.
MCI rent increases are subject to current statutory limits, including the post-HSTPA 2% annual cap. DHCR approval is required.
Owners should also distinguish between:
- A tenant-installed unit.
- An owner-installed permanent unit.
- A central system.
- Electrical service supplied as part of the rent.
- Electricity billed directly to the tenant.
Those facts can change the rent treatment. A cooling plan should therefore be reviewed by the owner’s attorney, accountant, and property manager before any new charge is placed on a rent-stabilized account.
What electrical and installation problems should owners expect?
Pre-war buildings in Bushwick, Bed-Stuy, Crown Heights, East New York, and Ridgewood may have electrical limitations that are not visible during a routine apartment inspection.
Planning should address:
- Existing panel capacity.
- Available amperage.
- Shared circuits.
- Overloaded bedroom or living-room circuits.
- Outlet condition.
- Extension-cord use.
- Service upgrades.
- Metering arrangements.
- Condenser placement for through-wall or split systems.
- Fire-escape clearance.
- Water drainage.
- Access for annual service.
A 2-to-4-family owner may have fewer units, but the electrical work can still be complex. One older property may need a service evaluation before it can safely support four new units. A larger property may have more equipment, but it may also have a more established electrical room, maintenance staff, and vendor relationships.
What does planning look like for a 30-unit building versus a 300-unit building?
A 30-unit building may be able to manage the process through a detailed spreadsheet and a single engineering review. The owner or manager should inventory each apartment, identify likely sleeping rooms, record existing AC equipment, and estimate the number of units that may be requested.
A 300-unit building requires a more formal program, including:
- A unit-by-unit asset inventory.
- A standardized request workflow.
- A central log of request dates and 60-day deadlines.
- Vendor capacity planning.
- Bulk equipment purchasing.
- Electrical and structural surveys.
- Tenant communication in required languages.
- Separate tracking for rent-stabilized apartments.
- Annual inspection scheduling.
- A reserve or capital-budget plan.
For example, if 25% of a 30-unit building’s apartments request one cooling unit, the first phase may involve approximately eight units. If the same request rate occurs in a 300-unit building, the initial workload could involve approximately 75 units, along with substantially more scheduling, storage, installation, and documentation.
The law does not guarantee that request rates will remain at 25%. Owners should model low, moderate, and high-demand scenarios.
What should Bushwick and Bed-Stuy owners do now?
Owners of small and mid-size properties can begin with the following steps:
Create a cooling inventory. Record every existing unit, its age, capacity, location, condition, and electrical circuit.
Review building records. Check certificates of occupancy, prior electrical work, permits, alteration records, and open violations.
Evaluate electrical capacity. Have a qualified professional identify whether current service and circuits can support the expected equipment.
Compare installation options. Analyze window units, through-wall systems, heat pumps, and central cooling based on cost, maintenance, code requirements, and long-term replacement needs.
Build a capital budget. Include equipment, installation, electrical upgrades, permits, engineering, repairs, annual inspections, and replacement reserves.
Separate regulated-unit procedures. Establish a process for tenant consent, IAI analysis, MCI review, rent registration, and DHCR documentation.
Create a request log. Track the date received, covered room, tenant communication, inspection findings, equipment selected, installation date, and maintenance history.
Coordinate with a property manager. A property management company in Bushwick or a property management company in Bed-Stuy can coordinate vendors, tenant notices, compliance records, and capital planning across multiple buildings.
Owners in East New York, Crown Heights, and Ridgewood can also review building compliance services and rental property management services as part of a broader compliance plan.
What is the NYCHA exception?
NYCHA does not follow the same tenant-request model as private owners. Instead, the law requires NYCHA to prepare a comprehensive cooling plan by January 1, 2028.
That plan must identify actions to provide adequate cooling and must establish initiatives to provide adequate cooling in at least 25% of NYCHA’s covered dwelling units by June 1, 2030. NYCHA’s plan must also address vulnerable populations and its existing 311 referral process.
This exception does not change the obligations of private owners of rent-stabilized or market-rate properties.
What should owners do before March 1, 2028?
Local Law 23 creates a multi-year planning window, not a reason to defer action. Owners should first determine whether the property can accommodate the likely equipment safely and legally.
The most practical priorities are electrical-capacity reviews, equipment inventories, rent-regulation analysis, vendor budgeting, and recordkeeping procedures. Final city rules may affect equipment specifications, request forms, inspection methods, and extension applications, so owners should revisit the plan as DOB and HPD publish additional guidance.
For a property in Bushwick, Bed-Stuy, East New York, Crown Heights, or Ridgewood, the immediate objective is a documented implementation plan that connects physical building conditions with tenant communications, capital budgeting, and rent-regulated compliance.
This article is for general educational purposes and is not legal, engineering, or DHCR advice. Owners should confirm current requirements with qualified professionals and review the official city and state guidance before taking action.