FISP Cycle 10A: The February 21, 2027 Deadline Every NYC Facade Contractor Needs to Understand

New York City has just under a year before the single largest compliance cliff in the history of its facade program. On February 21, 2027, every unrepaired Cycle 9 SWARMP condition on every building over six stories in the city automatically converts to UNSAFE, and the failure-to-correct meter starts running. If you own, manage, insure, finance, or restore these buildings, the next twelve months are the window in which the market actually moves. This guide walks through what Cycle 10A is, what changes on deadline day, how big the exposure is right now, and what facade restoration contractors should do about it starting this week.

What FISP Cycle 10A Is

FISP stands for the Facade Inspection Safety Program. It was originally enacted as Local Law 10 of 1980, rewritten and broadened as Local Law 11 of 1998, and rebranded FISP a few years later. Most New Yorkers still call it Local Law 11 out of habit. It applies to every building in the five boroughs taller than six stories, and it requires a physical, close-up inspection of the exterior walls and appurtenances on a recurring schedule.

The schedule is a five-year cycle. Each cycle is split into three staggered sub-cycles, A, B, and C, based on the last digit of the building's block number. Sub-cycle A buildings file first, B buildings follow about two years later, and C buildings bring up the rear. The point of the staggering is to smooth out inspection demand so that every facade engineer and contractor in the city is not chasing the same filings on the same week.

Cycle 10A is the first sub-cycle of the tenth overall cycle. It opened in early 2025 and closes on February 21, 2027. Every Cycle 10A building must have a QEWI-filed status report on the NYC Department of Buildings record by that date, and every unresolved Cycle 9 SWARMP condition on a Cycle 10A building must be repaired and re-filed as SAFE by the same date.

SAFE vs SWARMP vs UNSAFE (90-Second Version)

FISP reports land in one of three buckets. Each bucket comes with a different set of legal obligations and a different level of urgency for the owner.

• SAFE means the facade passed inspection. No action is required until the next cycle. These owners are not in the market for a restoration contractor.
• SWARMP stands for Safe With A Repair and Maintenance Program. It means the facade is not currently a public hazard, but conditions exist that will become unsafe if they are not repaired before the next cycle. SWARMP is a ticking clock, not a clean bill of health.
• UNSAFE means there is an immediate hazard. A sidewalk shed is required, a QEWI must file a repair plan, and the owner is on the hook for daily shed rental and DOB fines until the conditions are corrected.

For the full side-by-side, including who assigns each classification and what triggers a downgrade, see the companion guide, SWARMP vs UNSAFE vs SAFE.

The February 21, 2027 Cliff

February 21, 2027 is not a soft deadline. It is the date on which the Cycle 10A filing window closes, and it triggers four simultaneous events for every Cycle 10A building that still has open SWARMP conditions from Cycle 9.

• Every unrepaired Cycle 9 SWARMP condition automatically converts to UNSAFE. The owner no longer has the benefit of the doubt. The facade is now legally hazardous.
• NYC DOB issues violations against the building for the failed filing and for each converted UNSAFE condition. Violations attach to the building record and follow it through future financings and sales.
• A failure-to-correct civil penalty of $1,000 per month, per building begins accruing. It does not pause while the owner shops for a contractor or negotiates with insurance. It runs until the building is re-filed as SAFE.
• Sidewalk shed requirements kick in on any UNSAFE condition. Shed rental in New York City runs several thousand dollars a month per building and cannot be avoided while repairs are in progress.

Today there are already 1,590 buildings in UNSAFE status and another 5,583 in SWARMP per NYC DOB. A meaningful share of the SWARMP set is on the Cycle 10A clock. On deadline day, most of those will roll straight into the UNSAFE column unless a repair has been filed.

The Scale of the Problem Right Now

The current public NYC DOB facade record gives a clear read on how large the exposed surface already is, before the deadline has even arrived.

All three counts are drawn from the public NYC DOB Facades program record and the NYC Open Data facade filings dataset. The 1,847 figure is the one facade restoration contractors should pay the most attention to. Those are buildings with a live SWARMP obligation and no engineer attached, which means the owner has not yet started the Cycle 10 process at all. They are the most exposed and the least defended.

Is My Building Affected?

The simplest way to tell whether a given building is on the Cycle 10A clock is to walk this decision tree in order.

1. Is the building taller than six stories? If no, FISP does not apply at all. The building is exempt and the deadline is irrelevant.
2. What is the last filed Cycle 9 status? If the building filed SAFE for Cycle 9, it carries a clean record into Cycle 10 and there is no conversion risk on February 21, 2027. The owner still has to file Cycle 10A on time, but the cliff does not apply to them.
3. Is there a QEWI engineer of record for Cycle 10 yet? If no, the building is exposed. Without an engineer the owner cannot file a repair plan, cannot close out SWARMP conditions, and cannot submit a Cycle 10A report at all.
4. What is the sub-cycle, A, B, or C? If the building is in sub-cycle A, the February 21, 2027 date applies directly. If it is in B or C, the clock runs later but the same mechanics will apply when those windows close.

The QEWI Bottleneck

Only a Qualified Exterior Wall Inspector, a QEWI, can file a FISP report. A QEWI is a licensed professional engineer or registered architect with at least one year of specific facade inspection experience. The pool in New York is finite and it does not expand quickly. Every active QEWI already has a book of buildings they inspect every cycle. As Cycle 10A approaches, demand will spike in the third and fourth quarters of 2026 as owners who sat on their hands try to catch up at once. Contractors who wait until then will find that the best QEWIs are fully booked, shed supply is tight, and crew rates have moved up. The buildings that pre-book now will be on the calendar first.

Timeline to the Deadline

Here is the practical sequence of pressure points between now and the cliff.

1. Today

   Cycle 10A window is open. Engineer and crew availability is still normal. Owners are reachable and not yet panicked.
2. Q3 2026

   QEWI capacity tightens. The first wave of owners starts scrambling for engineers. Inspection lead times stretch from weeks to months.
3. Q4 2026

   Sidewalk shed supply chain tightens. Shed rental rates rise. Any owner not already under contract is now paying a rush premium.
4. January 2027

   DOB enforcement ramps. Pre-conversion reminder letters go out. The phones start ringing on their own.
5. February 21, 2027 — the cliff

   Unrepaired SWARMP converts to UNSAFE. Violations issue. $1,000 per month per building failure-to-correct penalties begin accruing.

What Facade Contractors Should Do Now

The next twelve months are the window. After that the work is still there, but the margin, the routing, and the client relationships will belong to the contractors who moved first. Five priorities.

• Build a target list of SWARMP buildings without a Cycle 10 architect of record. This is the 1,847-building set. They are the most exposed, the easiest to qualify, and they have the longest remaining decision runway.
• Prioritize by borough and building class. A pre-war Manhattan co-op, a 1970s Bronx rental, and a Brooklyn mixed-use walkup all require different crews, different estimates, and different sales conversations. Sort before you dial.
• Reach the beneficial owner, not the registered agent or the managing agent. Managing agents are paid to deflect facade conversations. The decision to spend six or seven figures on a restoration belongs to the person whose name is on the capital account.
• Lead with the fine math, not a sales pitch. A cold email that opens with the $1,000 per month failure-to-correct penalty, the shed cost, and the insurance friction gets replies. A cold email that opens with company credentials gets deleted.
• Pre-book your crews for the Q3 and Q4 2026 demand spike. Lock subcontractors now. Contractors who wait will be outbid on the same labor by the contractors who reserved it in advance.

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