SRR Apartment Registration Form (RR-1): ARRO Filing, Fees, and Late Penalties

Owners of rent-stabilized buildings handle NYC rent stabilization annual registration through New York State Homes and Community Renewal (HCR), filing between April 1 and July 31 each year to document every stabilized unit’s legal rent, tenant, lease terms, and services as of April 1.¹ Miss the window and the penalties stack fast: $500 per unregistered unit for each month you are late, plus a freeze on any rent increase until you catch up.

Who Has to File

If your building contains rent-stabilized apartments, you register. That applies to buildings in New York City under the Rent Stabilization Law and to buildings in municipalities outside the city that have adopted the Emergency Tenant Protection Act.² Registration is unit-by-unit. Exempt units still appear on the building forms but are marked as exempt.

A building that first becomes subject to rent stabilization has 90 days to file an initial registration.¹ Every year after that, the April-to-July annual filing applies.

What to Pull Together Before You Start

Have the following ready for each stabilized apartment:

Building address and HCR/DHCR registration number
Apartment number and room count
Full name of the current tenant on record
Legal regulated rent as of April 1
Actual rent paid, if the tenant pays a preferential rent below the legal maximum³
Lease start and expiration dates
Occupancy status (occupied, vacant, or exempt)
Equipment included in the rent (stove, refrigerator, dishwasher, air conditioner, and so on) and building-wide services (heat, elevator, laundry)

Keep leases, rent ledgers, and prior registrations within reach. Entering a figure from memory is how overcharge complaints start.

The Three Forms and the ARRO Portal

Annual registrations are filed electronically through Annual Rent Registration Online (ARRO), reached from the Owner Rent Regulation Applications page on the HCR website.⁴ After you sign in and pick the filing year and building, the system walks you through three forms:

RR-1(i), the Apartment Registration, filed once per apartment. It captures tenant name, legal rent, actual rent, lease dates, occupancy, and the equipment and services included in that unit’s rent.³
RR-2(i), the Building Summary, filed once per building. It lists total units, how many are stabilized, and how many fall under other rent regulation programs.
RR-3(i), the Building Services form, filed once per building. It covers building-wide services like heat, hot water, elevator service, and laundry that factor into the legal rent calculation.¹

Preferential Rents and Lease Dates

Two parts of the RR-1 cause more trouble than the rest combined. The first is preferential rent. If the tenant is paying below the legal maximum, both the legal regulated rent and the actual rent collected must appear on the form. Under the Housing Stability and Tenant Protection Act of 2019, HCR tracks preferential rents centrally, and a mismatch between what you report and what the tenant actually pays can seed an overcharge complaint.⁵

The second is the lease term. The start and expiration dates you enter should match the signed lease exactly. If a vacancy or renewal in the last year produced a lawful rent adjustment, the registration must reflect both the new rent and the new lease dates.

Fee and Submission

An annual administrative fee applies to each registered unit. The current amount is set by the Rent Stabilization Law and can be adjusted, so check HCR’s filing instructions before you submit.⁶ Nonpayment of the fee is treated as a charge owed to the City of New York; no separate penalty under the Rent Stabilization Code is imposed for nonpayment alone.⁷

After completing all three forms and paying, you certify the information and submit. Download or print the confirmation ARRO generates. That is your proof of timely filing.

Sending Each Tenant Their Copy

Filing is only half the obligation. By law, you must mail each tenant the portion of the registration that pertains to their apartment.¹ The tenant’s copy shows the legal rent on file with the state, the lease dates, and the services included. The requirement is statutory under both the Rent Stabilization Law and the Rent Stabilization Code.⁸

Send the copies by first-class mail and keep an internal log showing the date mailed and the address used for each tenant. HCR’s published sources do not fix an exact number of days by which service must occur, so mail the copies as soon after filing as you can. If a tenant later claims they never received notice, that log is your defense.

What Happens If You File Late or Not at All

Two penalties apply, and they stack.

A fine of $500 per unregistered unit for every month the registration is delinquent. A 20-unit building six months late reaches $60,000.¹
A rent-increase freeze. Until you file the missing registration, you cannot apply for or collect any rent above the legal regulated rent in effect on the date of the last properly filed registration. With no registration ever on file, the freeze reaches back to the base date rent.⁷

Filing a late registration lifts the freeze going forward. For proceedings started after July 1, 1991, a late filing also protects the owner from being found to have collected excess rent during the period before the late filing, provided the rent was otherwise lawful and the only deficiency was the untimely registration.⁷ That protection does not erase the monthly fines already accrued.

HSTPA raised the stakes again in 2019. Before then, treble damages for overcharges applied only when the overcharge was willful. Now, treble damages can be imposed on an owner whose rent was correct but who simply failed to file a proper registration.⁵

Keep the Records

Save every confirmation and receipt ARRO produces. Store the tenant notification log alongside the filed forms. General records should be kept for at least six years, the current statute of limitations for overcharge claims. Records of major capital improvements and individual apartment improvements should be kept indefinitely; failure to maintain them can trigger an unlimited lookback into rent history.⁵ If a complaint lands years from now, those are the documents HCR will ask for first.

1
New York State Homes and Community Renewal. Rent Registration
2
New York State Homes and Community Renewal. Rent Stabilization and Emergency Tenant Protection Act
3
New York State Division of Housing and Community Renewal. Initial Apartment Registration
4
Homes and Community Renewal. Owner Rent Regulation Applications
5
New York State Bar Association. NYS Housing Stability and Tenant Protection Act of 2019 Part II
6
New York State Homes and Community Renewal. Instructions for Filing Initial Rent Registration
7
Cornell Law Institute. New York Comp Codes R and Regs Tit 9 2528.4 – Penalty for Failure to Register
8
New York State Division of Housing and Community Renewal. Policy Statement 92-3 – Proof of Registration