Updated: December 18, 2025
Construction superintendents who hold multiple non‑major building jobs as of December 31, 2025, will be allowed to continue with those jobs past January 1, 2026.
The NYC Department of Buildings (DOB) included this clarification in a Service Notice dated December 18, 2025.
What this allows (and the key limitation)
If a Construction Superintendent (CS) is the primary CS on multiple non‑major building jobs as of 12/31/25:
- The CS may continue serving as primary CS on those same, existing jobs into 2026.
- The CS may not be designated as primary CS on additional jobs after 1/1/26 while they still hold more than one of those existing jobs.
- As existing jobs finish (or the CS removes themself), the CS can continue with the remaining existing jobs — but cannot “replace” completed jobs with new ones.
DOB’s example, simplified:
- CS holds 3 non‑major jobs on 12/31/25 → can keep those 3 in 2026
- When one finishes → CS can keep the remaining 2, but cannot take on a new third
- When the second finishes → CS can keep the remaining 1, but cannot take on a new second
Important deadline: this allowance ends January 1, 2027
DOB stated the allowance to hold multiple existing non‑major jobs will end January 1, 2027. At that time, any CS still holding multiple non‑major jobs from December 31, 2025 will have to drop jobs and will only be able to hold one.
Reminder: new CS job limitations begin January 1, 2026 (secondary)
The same Service Notice also reminded the industry that under Local Law 149 of 2021, beginning January 1, 2026, a Construction Superintendent will be limited to being designated as the primary CS on no more than one (1) job — either a major building job or a non‑major building job.
Competent Person allowance (through Dec. 31, 2026)
For both major and non‑major building jobs, DOB noted that a CS may continue to designate a Competent Person in accordance with NYC Building Code Section 3301.13.12 through December 31, 2026.
This allowance sunsets January 1, 2027. After that date, a CS will be required to be on-site during all times work is occurring, except for certain activities exempted by Section 3301.13.7.
Items NOT impacted
DOB stated these changes do not impact:
- A CS serving in a backup/non-primary role (per exception #5 to Section 3301.13.6)
- A CS serving as primary CS for multiple non‑major jobs on the same lot or contiguous lots, subject to DOB approval
Recommended next steps
To reduce risk of project disruption:
- Confirm which jobs your CS is designated as primary on today
- If relying on this allowance, document the CS’s active non‑major jobs as of December 31, 2025
- Plan staffing for 2026 filings now, especially if you anticipate new jobs that would require a different primary CS
If you’re part of our New York City construction industry and would like to keep informed of new developments and how your project could be affected, we invite you to sign up for our mailing list. We’ll also send you our complimentary, comprehensive guide to New York City DOB’s new Chapter 33 Building Code revisions.
Cahill Strategies Construction Solutions Guide to NYC Building Code Chapter 33 Revisions
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The 100-page book is meticulously organized and can be used as a handy reference when many common issues arise. In each section, the specific revisions are highlighted, and the new information is presented in a clear and practical manner with further explanation on why the change is so important. All of this, reviewed and vetted by one of New York’s longest serving, former DOB professionals – Cahill Strategies’ Director of Construction Code & Safety, Bobby D’Alessio.
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Get to know Bobby D’Alessio
Robert “Bobby” D’Alessio, is a former New York City Department of Buildings Senior Executive Director of Construction Safety. Mr. D’Alessio’s focus is predominately in the areas of construction code and safety analysis for our clients’ major new building and renovation projects in the New York City and surrounding regions.
As Cahill Strategies’ Director of Construction Code and Safety, Bobby brings an unparalleled level of knowledge and practical experience to our growing construction solutions practice area.
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Kevin, the Vice President of Construction Solutions at Cahill Strategies, brings a wealth of experience in the New York construction industry to his role. He has a strong track record of guiding clients through complex building processes, with a range of successful projects under his belt, including commercial and residential developments, infrastructure and transportation projects, and various utility matters.
