Lead Paint Rules for Property Managers 2026: Disclosure and RRP

If you lease housing built before 1978, federal law requires you to give the tenant the EPA lead pamphlet, disclose any known lead-based paint or hazards and hand over available reports, and attach a signed Lead Warning Statement before the tenant is bound by the lease. You and the owner then keep the signed form for at least three years.¹ Any paid work that disturbs paint in those units falls under EPA's Renovation, Repair and Painting (RRP) rule, which means a Lead-Safe Certified firm and a certified renovator on the job.² New for 2026: EPA's lower dust-lead standards reached their compliance date on January 12, 2026, federal penalty caps were frozen at 2025 levels, and Delaware and New Jersey added state duties on top of the federal floor.³⁴⁵⁶

Related: federal rules for rental operators and landlord disclosures by state.

Which units are covered

The federal disclosure rule applies to "target housing," which the statute defines as housing built before 1978, except housing for the elderly or persons with disabilities and 0-bedroom dwellings, unless a child under 6 lives or is expected to live there.⁷ EPA rewrote its regulatory definition in the 2024 dust-lead rule to match that statutory wording, which Congress amended in 2017.⁸ A 0-bedroom dwelling is one where the living area is not separated from the sleeping area, including studios and rentals of individual rooms. "Housing for the elderly" means housing reserved for households with a member 62 or older at initial occupancy.¹

Within target housing, the disclosure rule does not apply to:¹

• Leases of units a certified inspector has found to be lead-based paint free.
• Short-term leases of 100 days or less where no renewal or extension can occur.
• Renewals where the full disclosure was already made and no new information has come into the lessor's possession.
• Sales at foreclosure.

The studio exemption is not absolute: if a child under 6 will live there, treat the unit as covered. And "lead-free" means a certified inspector's written finding, not an owner's belief that the paint was replaced. EPA's own summary lists the same exemptions.⁹

The federal disclosure, step by step

Under 40 CFR 745.107 and 745.113, all of this happens before the tenant is obligated under the lease. If the tenant has already made an offer, the lessor completes the disclosure before accepting it and lets the tenant amend the offer.¹

"Available" means records in the lessor's possession or reasonably obtainable at the time.¹ At a management takeover, ask the owner and the prior manager in writing for any lead reports before the first new lease.

The rule does not require testing. It says nothing in it implies an obligation to conduct evaluation or reduction activities.¹ But anything you learn becomes known information for every later lease, and it ends the renewal exemption.

The warning must be in the language of the lease, as an attachment or inside the lease.¹ EPA publishes sample lessor disclosure forms in English and Spanish and allows electronic delivery with the tenant's consent and a statement of the right to paper copies.⁹ The tenant move-in playbook shows where the form fits in the signing sequence.

Property managers are "agents" with their own duty

The rule defines an agent as any party who contracts with a lessor, or with the lessor's representative, to lease target housing.¹ A management agreement that includes leasing makes you one. Under 40 CFR 745.115, each agent must ensure compliance with the whole subpart, and to do that must:¹

1. Inform the lessor of its obligations under sections 745.107 and 745.113.
2. Ensure the lessor has done everything those sections require, or personally ensure compliance.

The one shield: an agent who informed the lessor is not liable for hazards the lessor knew about but did not disclose to the agent.¹ That only works if you can prove the notice, so put the owner's lead duties in the management agreement or a signed acknowledgment. The statute itself makes the agent responsible for ensuring compliance on the lessor's behalf.¹⁰

Penalties in 2026

There are three layers of exposure for disclosure violations.

• HUD civil penalty. HUD may assess up to $22,263 per violation against anyone who knowingly violates 42 U.S.C. 4852d.¹¹
• EPA civil penalty. EPA's penalty table lists the same $22,263 maximum for disclosure violations enforced under the Toxic Substances Control Act, for penalties assessed on or after January 8, 2025.¹²
• Private suits. A person who knowingly violates the disclosure law is jointly and severally liable to the tenant for three times the tenant's damages, and a court may award attorney fees and expert costs to a tenant who wins.¹⁰

For RRP and other TSCA violations, the current maximum under 15 U.S.C. 2615(a)(1) is $49,772 per violation.¹² The statute treats each day a violation continues as a separate violation.¹³

These amounts did not rise this year. The Office of Management and Budget told agencies on April 17, 2026 that there would be no 2026 inflation adjustment, because the government shutdown kept the Bureau of Labor Statistics from producing October 2025 CPI data. HUD's September 24, 2026 notice keeps its penalties at 2025 levels.⁴ EPA's table still shows the January 2025 amounts, and the older figures printed in 40 CFR 745.118 defer to it.¹²¹

The RRP rule for repairs and turnovers

The RRP rule covers renovations performed for compensation in target housing. "Renovation" means modifying a structure in a way that disturbs painted surfaces, including window repair, surface prep, removing building components, weatherization and interim controls.² EPA says the rule reaches owners who rent out all or part of a home.¹⁴

The main exclusion is minor repair and maintenance: 6 square feet or less of painted surface per room inside, or 20 square feet or less outside. Window replacement, demolition of painted surfaces and prohibited practices never qualify, and jobs in the same room within 30 days count as one job.² Turnover is where managers get caught: patching and repainting a bedroom easily passes 6 square feet.

Work is also exempt when a certified inspector, risk assessor or renovator has documented that the affected components are not lead-based paint. Emergency renovations skip the pamphlet and some work practices, but not cleaning, cleaning verification or recordkeeping.²

Who must be certified

Since April 22, 2010, a firm may not perform, offer or claim to perform covered renovations without firm certification, and each job must be directed by a certified renovator.² Managers long relied on two EPA FAQ answers suggesting a company that hired out all the work did not need certification. EPA withdrew both effective March 21, 2022.¹⁵ Its enforcement office then wrote that management companies that perform, offer or claim to perform renovations must be certified and must ensure their employees and outside contractors follow the rule.¹⁶ If your company does none of that, EPA says to hire only Lead-Safe Certified firms.¹⁷

Firm certification lasts up to five years.² Fourteen states certify firms through their own EPA-authorized programs: Alabama, Delaware, Georgia, Iowa, Kansas, Massachusetts, Mississippi, North Carolina, Oklahoma, Oregon, Rhode Island, Utah, Vermont and Wisconsin.¹⁴

Pamphlet and records

No more than 60 days before work, the firm must give the Renovate Right pamphlet to the owner and an adult occupant, documented by a signed receipt, a certificate of mailing at least 7 days ahead, or (for occupants) a certified delivery attempt. Common-area work needs notice to each affected unit or posted signs. The firm keeps records for 3 years and must give the owner and occupant its compliance information by the final invoice or within 30 days of completion, whichever is earlier.²

What to require from vendors

Before a painter, handyman, window installer, plumber or HVAC tech touches a pre-1978 unit, collect and file:

• The firm's current EPA or state Lead-Safe certificate and its expiration date.
• The name and certificate of the renovator assigned to your jobs.
• A written commitment to deliver pamphlet receipts and the end-of-job recordkeeping checklist with every invoice.
• An agreement not to use open-flame burning, unshrouded power sanding or grinding, or heat guns at 1,100 degrees Fahrenheit or higher, which the rule prohibits.²

Check certificates at vendor intake, not at dispatch. See the vendor onboarding playbook.

The 2024 dust-lead rule and its 2026 compliance date

On November 12, 2024, EPA finalized a rule lowering the dust-lead hazard standard to "any reportable level" of lead and cutting post-abatement clearance levels. The rule took effect January 13, 2025, with a one-year compliance period for the new standards so laboratories could adjust.⁸ EPA confirms that compliance for the new standards and the abatement report language was January 12, 2026, in EPA-administered jurisdictions.³ EPA published a correction on July 9, 2025, restoring post-abatement text that had been deleted by mistake when the rule took effect.¹⁸

Sources: 40 CFR 745.65(b) and 745.227(e)(8)(viii).¹⁹²⁰

None of this requires an owner to test.¹⁹ But when someone does, any measurable lead in a dust wipe is now a hazard, and abatement reports that end below the action levels but above the reportable level must state that some dust-lead hazards remain.⁸ A report like that is known information for your next disclosure.¹ Timing varies by state. The rule names Alaska, Arizona, Florida, Idaho, Montana, Nevada, New Mexico, New York, South Carolina, South Dakota and Wyoming among EPA-run jurisdictions; states with authorized programs have until January 11, 2027 to show EPA they meet the new requirements.⁸

HUD-assisted housing and voucher units

HUD's Lead Safe Housing Rule, 24 CFR part 35, adds duties for assisted pre-1978 housing. For Housing Choice Vouchers and other tenant-based assistance, subpart M covers units occupied or to be occupied by a child under 6, plus the common areas and exterior surfaces serving them.²¹

Unfinished work leaves the unit in violation of Housing Quality Standards.²¹

HUD's safe work practices apply above 20 square feet outside, 2 square feet in any interior room, or 10 percent of a small component such as a sill.²² That 2 square foot trigger is far below the RRP rule's 6. Part 35 exempts post-1977 construction, 0-bedroom units and SROs, elderly and disability housing unless a child under 6 lives there, and property found lead-free by inspection. For dust, it uses standards at least as protective as EPA's whenever EPA's are in effect.²³

State lead-safe laws: five examples

The federal rule does not relieve a lessor or agent from state or local lead requirements.¹

Delaware (enacted, not yet started). 85 Del. Laws c. 98, approved July 21, 2025, requires a state-approved lead inspector's certificate that each rental built before 1978 is "lead free" or "lead safe," filed with the Department of Health and Social Services before a new tenant's rental agreement begins and no later than four years after implementation. Leases must disclose the certification, and a landlord filing for possession must show the court the property complies. Penalties run up to $100 per day per unit for owners of 19 or fewer units, rising to $1,000 per day per unit for owners of 20 or more. The duties start 12 months after the Delaware State Housing Authority gives notice that funding and final regulations are in place, or on March 1, 2028, whichever is earlier.⁵

New Jersey (in force). P.L. 2021, c. 182 requires lead inspections of rental dwellings, first at turnover or by July 22, 2024, then every three years or at turnover, whichever is earlier. A lead-safe certificate lasts two years and avoids a turnover inspection while valid. Exempt: post-1977 buildings, seasonal rentals under six months, certified lead-free dwellings, and multiple dwellings registered with DCA for ten years with no outstanding lead violations. Owners who do not cure within 30 days face up to $1,000 per week.²⁴

Maryland (in force). The state lead risk law covers rentals built before 1978 since January 1, 2015.²⁵ Owners register each property with the Department of the Environment, listing any property manager, and renew yearly.²⁶²⁷ Before each new tenant moves in, peeling paint must be fixed and the unit must pass a lead dust test and inspection.²⁸ At lease signing the tenant gets the state notice of rights with the current inspection certificate and a lead information packet, both repeated at least every two years.²⁹³⁰

Rhode Island (in force). Owners of pre-1978 rentals not certified lead safe or lead free must complete a lead hazard awareness seminar (or send a designee), evaluate the unit, meet the lead hazard mitigation standard, give tenants a copy of the independent clearance inspection, and fix hazards within 30 days of a tenant's notice when an at-risk occupant lives there. The section was last amended effective June 29, 2025.³¹ A clearance is valid for two years or until the next turnover, whichever is longer.³²

Massachusetts (in force). Whenever a child under 6 lives in a home with dangerous levels of lead in paint, plaster or other accessible materials, the owner must abate or contain it, fully or through interim controls under a licensed inspector's plan.³³ That is a duty to fix, not just to disclose. Cities may add their own rules, so check local ordinances too.

Lead in drinking water: New Jersey's new disclosure

The federal rule covers paint, not plumbing. New Jersey's P.L. 2025, c. 144, approved September 19, 2025, requires a landlord to give each prospective or current tenant a "Lead In Drinking Water Disclosure" before signing a lease or renewal. The disclosure must state when the building was built and that housing built before 1986 may have a lead service line or interior lead plumbing, acknowledge any notice from the water system of a lead or unknown-material service line, and attach any lead action level exceedance notice from the past three years (unless it was received more than 12 months earlier and corrected).⁶ Exempt: buildings built after 1986, buildings on a line the water system has determined is not lead, and seasonal rentals. In a written lease it can be a separately signed rider in at least 12-point type.⁶

The duty begins 90 days after the state publishes the health notice and model form.⁶ DCA has posted its model form.³⁴ A New Jersey law firm (a secondary source; we could not locate the New Jersey Register notice online) puts the start date at November 15, 2026.³⁵ After a 15-day cure period, penalties are $100, $500, then $1,000. A landlord who blocks a water system's lead line replacement lets the tenant end the lease without penalty.⁶

What to do now

• Tag every unit by year built. Flag pre-1978 units for paint rules, and in New Jersey, units built 1986 or earlier for the water disclosure.
• Document each exemption, and treat a studio as covered when a child under 6 will live there.
• Add the lessor disclosure, Lead Warning Statement, pamphlet receipt and agent statement to every covered lease packet. Re-disclose at renewal when new information exists, and keep signed copies at least 3 years.
• Send each owner a written notice of their duties under 40 CFR 745.107 and 745.113 and ask in writing what lead records they hold. File the reply.
• If your company performs, offers or claims to perform renovations, get firm certification and certified renovators.
• Require a current Lead-Safe certificate from every vendor who works in pre-1978 units, and collect Renovate Right receipts and job records with each invoice.
• Measure turnover scopes. Interior work over 6 square feet per room (2 square feet in HUD-assisted units) or any window replacement triggers lead-safe practices.
• Disclose dust-lead hazards shown in any new lab report under the post-January 12, 2026 standard.
• For voucher units with a child under 6, budget for paint stabilization and clearance before move-in.
• Calendar state deadlines: New Jersey turnover inspections and the water disclosure, Maryland annual registration, and Delaware's implementation date (no later than March 1, 2028). The compliance calendar playbook shows one way to track them.

This article explains what the rules say. It is not legal advice for a specific property.