NYC DOB issued an Industry Notice on December 18, 2025 clarifying that beginning January 1, 2026, a Construction Superintendent (CS) may be designated as the primary Construction Superintendent on no more than one job, whether that job is a major building or a non-major building project.
The notice also explains (1) a transition rule for Construction Superintendents who already hold multiple non-major jobs as of December 31, 2025, and (2) a Competent Person designation timeline that changes again in 2027.
Key Dates (Quick Reference)
- January 1, 2026: A Construction Superintendent may be designated as primary CS on only one job total (major or non-major).
- December 31, 2025 → 2026 transition: If a CS already holds multiple non-major jobs as of December 31, 2025, those specific pre-existing jobs may continue into 2026; however, no new primary CS designations may be added after January 1, 2026, and completed jobs may not be replaced.
- January 1, 2027: The transition allowance ends. Any CS still holding multiple non-major jobs from December 31, 2025 must be reduced to one job total, and the Competent Person designation sunsets, subject to limited code-based exceptions.
Because primary CS designations are limited beginning in 2026, early review and planning can help avoid scheduling constraints at project start.
What Changed on January 1, 2026
NYC DOB clarified that starting January 1, 2026, a Construction Superintendent may be designated as the primary CS on no more than one job, regardless of whether the job is classified as a major building or non-major building project.
Practical takeaway: If a CS is already designated as primary on one job, that individual cannot be assigned as primary on any additional job after January 1, 2026.
For reference, see the official NYC DOB Industry Notice (PDF) and Local Law 149 of 2021 (PDF).
Current Limits Before 2026 (Context)
NYC DOB's Industry Notice reiterates that Construction Superintendent job limits have phased down over time, culminating in the one-job rule effective January 1, 2026. Many teams still reference older limits, which no longer apply.
Summary of phase-down under Local Law 149 of 2021:
- Prior to 2022: Up to 10 active jobs
- June 1, 2022: Reduced to 5 active jobs
- January 1, 2024: Reduced to 3 non-major jobs or 1 major job
- January 1, 2026: Final phase - only 1 primary job total, whether major or non-major
Key takeaway: Any prior allowance to manage multiple jobs as primary collapses to one total job beginning in 2026.
Transition Rule for Multiple Non-Major Jobs Held as of December 31, 2025
NYC DOB provides a transition rule for Construction Superintendents who are already designated as primary on multiple non-major building jobs as of December 31, 2025:
- Those existing non-major jobs may continue after January 1, 2026, without immediate removal.
- However, the CS may not be designated as primary on any additional job after January 1, 2026.
- As each preexisting job is completed (or the CS removes themself), the CS may not replace it with a new primary designation.
- This transition allowance expires on January 1, 2027, at which point the CS must hold only one primary job.
Competent Person Designation Timeline (Through 2026, Changes in 2027)
The DOB notice also addresses Competent Person coverage:
- A Competent Person may continue to be designated through December 31, 2026, as referenced by NYC Building Code §3301.13.12.
- Beginning January 1, 2027, the Competent Person allowance sunsets, and the Construction Superintendent must be on site during all times work is occurring, except for limited exempt activities referenced by NYC Building Code §3301.13.7.
Exceptions and Clarifications (Backup/Non-Primary Roles; Contiguous Lots)
DOB clarifies that the "one-job" limitation does not change certain scenarios, including:
- CS acting in a backup/non-primary role (per exception #5 to Section 3301.13.6 of the NYC Building Code), and
- Certain cases involving the same lot or contiguous lots, subject to DOB approval.
What This Means for Contractors and Developers (2026–2027)
As the Construction Superintendent one-job limitation takes full effect in 2026, and the Competent Person allowance sunsets in 2027, many industry participants expect increased demand for licensed Construction Superintendents, particularly for projects that previously relied on a single superintendent across multiple active sites.
While actual impacts will vary by project type, scale, and timing, contractors and developers should plan for the following:
- Increased competition for experienced, licensed Construction Superintendents, especially during peak construction periods
- Potential scheduling constraints or delays if primary CS availability is not secured early in the project lifecycle
Recommended preparation steps
To support a smooth transition, contractors and developers should begin preparing now:
- Review 2026–2027 project schedules and staffing plans to identify where primary CS designations may overlap
- Anticipate the need for additional licensed superintendents for projects previously covered by shared supervision
- Adjust project budgets and staffing assumptions to reflect increased supervision requirements
Early planning and designation review can help reduce scheduling constraints and support uninterrupted project starts as the 2026–2027 enforcement timelines approach.
FAQ - NYC Construction Superintendent One-Job Rule (2026-2027)
Q1: When does the NYC Construction Superintendent one-job rule start?
A: NYC DOB clarified the one-job limit for primary CS designations begins January 1, 2026.
Q2: Can a CS be primary on more than one non-major job after Jan 1, 2026?
A: If those non-major jobs were already held as of Dec 31, 2025, the CS may continue them, but cannot add any new primary jobs.
Q3: What happens on Jan 1, 2027?
A: The transition allowance ends; a CS holding multiple non-major jobs from 12/31/2025 must reduce to one job. The Competent Person allowance also sunsets (with limited exemptions referenced by code).
Q4: Does the one-job rule affect backup or non-primary superintendent roles?
A: DOB indicates the decrease does not affect CSs serving in backup/non-primary roles under the relevant exception.
Q5: Does the one-job rule apply to multiple jobs on the same or contiguous lots?
A: DOB indicates contiguous-lot scenarios may be treated differently, subject to DOB approval.
Q6: What is the biggest risk for projects starting in 2026?
A: Discovering late that your intended primary CS is already assigned, which can delay new starts. A designation tracker and step-down plan avoids this.