New York co-op, condominium, and homeowners associations operate under a complex framework including the New York Business Corporation Law (co-ops), the New York Condominium Act (Article 9-B of the Real Property Law), and — for New York City buildings — significant local law requirements. From 2021 through 2025, New York co-op and condo boards have faced new obligations around virtual meetings, greenhouse gas emissions, and federal reporting. Here is what matters most.
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2021: Virtual Co-op Meetings Authorized Permanently
Assembly Bill A1237 — Virtual Co-op Meetings Authorized
New York co-op boards gained permanent authority to hold annual and board meetings by electronic communication under Business Corporation Law §602. This change — enacted in 2021 — is permanent, not a COVID-19 emergency measure. Co-op boards that want to hold virtual meetings no longer need to rely on emergency provisions or governing document amendments; the BCL now authorizes it at the board's discretion.
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2024: NYC Local Law 97 and Federal Beneficial Ownership Reporting
NYC Local Law 97 (LL97) — Greenhouse Gas Emissions Caps
New York City buildings over 25,000 square feet — including co-ops and condominiums — are subject to greenhouse gas emissions caps under Local Law 97. The caps became effective starting in 2024, and the first annual emissions compliance reports were due **May 1, 2025**. Non-compliant buildings face significant annual fines calculated on a per-ton basis above their cap.
Co-op and condo boards in New York City with large buildings should:
- Determine whether their building meets the 25,000 sq. ft. threshold.
- Calculate their building's 2024 greenhouse gas emissions.
- File the annual compliance report by May 1 of each year.
- Develop a capital improvement plan to reduce emissions if the building is above its cap.
Corporate Transparency Act (Federal) — Beneficial Ownership Reporting
The federal Corporate Transparency Act, enacted in 2021 and implemented in 2024, may require co-ops, condo associations, and HOAs to report beneficial ownership information to the U.S. Financial Crimes Enforcement Network (FinCEN). As of 2025, enforcement has been paused for many entities following court orders challenging the Act's constitutionality. New York boards should consult counsel to determine their current reporting status before any future enforcement deadlines.
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What New York HOA and Co-op Boards Should Do Now
1. Confirm your co-op's governing documents permit virtual meetings — or rely directly on BCL §602 (A1237, 2021).
2. If your NYC building is over 25,000 sq. ft., file your 2024 emissions compliance report by May 1, 2025 deadline (NYC LL97).
3. Develop a building energy efficiency and emissions reduction roadmap if your building is above the LL97 cap.
4. Consult counsel on Corporate Transparency Act status — determine whether your entity is required to file beneficial ownership reports and monitor the current enforcement status.
5. For co-ops outside NYC, monitor state-level legislation and consult counsel on any applicable virtual meeting or reporting changes.
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How APM Provides Remote HOA Management in New York
APM provides professional remote HOA and condo management to New York boards through our HOA Alchemy platform, serving communities in New York City, Buffalo, Rochester, and across the state. Our compliance team tracks New York HOA law changes and NYC local law requirements to help boards stay ahead of compliance deadlines. Contact us at billing@apmhoa.com or visit [apmhoa.com/remote-hoa-management/new-york](https://www.apmhoa.com/remote-hoa-management/new-york) for a free remote management proposal.
*This article is for general informational purposes only and does not constitute legal advice. For questions specific to your association, consult a licensed New York attorney.*
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