The 2026 Guide to WTPA, SST Cards, DOB Records and Stop Work Orders
New York contractor compliance means proving, on demand, that every worker was paid under state wage law, trained under Local Law 196, protected under Building Code Chapter 33 and recorded under OSHA rules. The NYC Department of Buildings oversees nearly 42,000 active construction sites, and its Construction Safety Report 2025 shows building construction injuries down more than 33% from 2024 to 2025, while fatalities rose to 10.
That burden runs past your own crews to every subcontractor tier. BiltOn is designed for this problem: a Safety Intelligence platform that links every worker to every safety record, so a GC can show an inspector, a carrier or a court the proof in minutes. If you are comparing tools, start with our guide to the best safety management platform in New York. This guide is educational and not legal advice, so confirm specific obligations with counsel.
Safety Intelligence: verified, worker-level field data turned into real-time insight that predicts risk and recommends action.
Section 198-e: the New York Labor Law provision that makes a contractor liable for wages its subcontractors at any tier fail to pay on a covered construction contract.
What does it mean to be a compliant GC in New York City?
A compliant GC in New York City can prove, for its own crews and every subcontractor, that wage law, worker training, site safeguards and federal recordkeeping were met on any given day.
The four layers of NYC compliance
Wages and labor (NYS DOL). The Wage Theft Prevention Act governs pay notices, wage statements and damages.
Worker training (NYC DOB). Local Law 196 of 2017 sets Site Safety Training requirements on covered sites.
Site safeguards and records (NYC DOB). Building Code Chapter 33 covers safeguards during construction and the documents a site keeps.
Federal recordkeeping (OSHA). 29 CFR 1904 governs injury and illness logs and reporting.
Why the GC carries the subcontractor's risk
Wage liability climbs the subcontract chain under Section 198-e, and DOB holds permit holders responsible for untrained workers on their sites. Nationally, the Bureau of Labor Statistics counted 1,032 fatal injuries among construction and extraction workers in 2024. We cover the field side in construction safety compliance workflows, the business case in how compliance software protects construction and the exposure in ways construction companies are vulnerable to on-site liability.
What does the NY Wage Theft Prevention Act require?
The New York Wage Theft Prevention Act requires employers to give each new hire a written notice of pay rate and to give every employee a wage statement with each payment of wages. Missing paperwork carries per-day damages under Labor Law section 198.
What goes on a wage theft prevention notice
Our explainer on what is a wage theft prevention notice walks through the form. Per the NYS Department of Labor's Notice of Pay Rate guidance, it must include these items.
Rate or rates of pay, including the overtime rate when it applies
How the employee is paid, such as by the hour, shift, day, week or commission
The regular payday
The employer's official name and any other names used for business (DBA)
The address and phone number of the employer's main office or principal location
Allowances taken as part of the minimum wage, such as tips, meal and lodging deductions
Which languages the notice must be in
Use English plus the employee's primary language when DOL offers a translation: Spanish, Chinese, Haitian Creole, Korean, Polish or Russian.
Wage statements and penalties
Employers must also give a wage statement each payday, as DOL's wage theft and labor standards page explains, with the fields listed in its Guidelines for Wage Statement Provisions (LS 45). Under New York Labor Law section 198, an employee who does not receive the notice within ten business days of starting work can recover $50 per workday, up to $5,000. A missing wage statement carries $250 per workday, also capped at $5,000, plus costs and attorney's fees, and wage claims can reach back six years.
For WTPA meaning and requirements by role, read what New York contractors must know about the WTPA in 2026 and our Wage Theft Prevention Act guide.
Is the GC liable for a subcontractor's unpaid wages?
Yes, on covered private construction contracts. Labor Law section 198-e makes a contractor jointly and severally liable for wage debts that subcontractors at any tier owe their workers, and a waiver signed by an employee or subcontractor is not valid except as the statute allows.
How NYLL 198-e works
Reach-back. Liability covers claims occurring no earlier than three years before the action begins.
Notice and cure. The worker must give the contractor notice first and cannot sue until ten business days later, or at all if the contractor corrects the violation.
Exclusions. Labor Law Article 8 public work, home improvement contracts for owner-occupied dwellings and most one- and two-family home contracts fall outside the section.
Recovery. The GC keeps its right to recover from the subcontractor.
What to collect from every subcontractor
Collect signed pay notices, payroll records that match the hours your site logged, a worker list tied to each subcontractor's legal entity, and current insurance and training credentials. BiltOn ties each verified check-in to the worker's employer, which gives your compliance lead a daily record to compare against payroll. Our guides on subcontractor wage liability under the WTPA and tracking worker certifications and COIs show how.
What enforcement looks like in NYC
On March 12, 2026, the Manhattan District Attorney announced that an electrical subcontractor and its president pleaded guilty to a scheme that stole at least $325,000 from at least seven workers on School Construction Authority projects. In an older 2023 case, the NYC Comptroller reached a $516,500 settlement with four prime contractors over payroll fraud by a subcontractor that had disappeared. Both were public work, and both show the prime contractor paying when the subcontractor cannot.
Who needs an SST card, and how do you verify it at the gate?
Under Local Law 196 of 2017, workers on sites that require a site safety manager, coordinator or superintendent need a Site Safety Training (SST) card. The DOB SST FAQ sets at least 40 hours for workers and 62 for supervisors, and each card must be validated in DOB Training Connect before the worker enters.
Which sites and workers need SST
Cards expire after five years, and holders must take refresher training in the 12 months before expiration. DOB penalizes the site, not the worker: civil penalties reach $5,000 per untrained worker for the owner, the permit holder and the employer, and a permit holder without a log proving everyone is trained faces $2,500.
How to verify SST cards at check-in
Scan or enter each card at the gate before the shift starts.
Validate it in the DOB Training Connect app, which DOB encourages site safety professionals to use.
Log the result against the worker's profile and employer.
Turn the worker away and notify the subcontractor when a card is invalid, expired or missing.
Our walkthrough on how to verify SST cards on a NYC jobsite covers each step, construction site access control explains how check-in becomes a verified identity, and QR code sign-in vs facial verification compares methods.
The 2026 Redcode card change
On September 8, 2026, the Brooklyn District Attorney's Office announced that Redcode, Inc. was indicted for fraudulently issuing SST cards, and DOB invalidated every SST certificate Redcode issued. Per DOB's SST worker information page, affected workers have until December 7, 2026 to replace them.
Customer proof point: Broadway Construction Group. "We standardize all name entries against the cards that are issued by the Building Department of the City of New York," says David Rivera, Director of Operations. Read how BCG made every worker on site verified and accountable.
Lettire reports onboarding time per worker fell from 6 hours to 2 hours (client-reported) after it moved to self-service, as told in how Lettire cut onboarding time. As Greg Stewart, Director of Preconstruction and Operations, put it: "If your safety guy is stuck onboarding instead of walking the site, that's a gap in your coverage." Archstone produced a verified crew list for a DOB inspector within seconds after it replaced outdated badging.
What triggers a DOB stop work order, and how do you get it lifted?
DOB issues a stop work order when inspectors find unsafe work or conditions. A Full order prohibits all work except remedial work to make the site safe, and a Partial order stops named work or one area. Working against an order costs $6,000 for a first offense and $12,000 for each one after.
The most common stop work order conditions
For Quarter 3 of 2026, the DOB stop work order top 10 list shows these shares of violations issued.
Miscellaneous violations: 21.1%
Work without a permit: 17.8%
Work not conforming to approved construction documents: 11.4%
Failure to maintain or display Chapter 33 documents on site: 5.9%
Electrical work without a permit: 5.8%
Failure to safeguard persons and property: 5.2%
DOB's stop work order guide shows which conditions draw a Full or a Partial order.
How to get a stop work order lifted
The DOB stop work order page sets out five steps.
Correct all violating conditions cited in the order.
For major buildings, submit a Certificate of Correction for outstanding ECB violations.
Request a re-inspection from the issuing unit.
Pay any applicable civil penalties.
Ask the issuing unit to rescind the order.
The penalties trace to Local Law 157 of 2017, and open violations stay visible on DOB's violations lookup.
How to avoid one in the first place
Our guides on stop work orders in NYC and how to avoid stop work orders in NYC go condition by condition.
Customer proof point: Hunter Roberts. Hunter Roberts used BiltOn to keep jobs on track: within six months, pre-shift plan completion rose from 67% to 98% (client-reported). "The difference between knowing you're compliant and being able to prove it in real time is everything," says Corey Jones, VP of Corporate Safety.
Which site safety records must be on site, and can they be digital?
Chapter 33 of the NYC Building Code requires site safety documents to stay at the jobsite for the duration of the job and be available to DOB on request. Since Buildings Bulletin 2024-007, issued December 19, 2024, every jobsite may keep them electronically if its system meets the bulletin's conditions.
What Chapter 33 expects on site
Covered documents include the site safety log, the construction superintendent log, safety orientation and refresher records, pre-shift safety meeting records, and sidewalk shed and scaffold inspection documents.
What Buildings Bulletin 2024-007 changed
A dedicated device. A tablet with at least a 10-inch screen must be on site with "sufficient power, connectivity, and access for the department to readily view the electronic document."
Email or print on demand. Documents must be readily emailed to DOB as a PDF or printed at the site.
A true document system. "Scans of paper documents, or malleable word or excel files, do not constitute compliance with this bulletin."
Locked, signed records. Records cannot be edited once created, and each carries a time stamp and digital fingerprint showing who signed and when.
Retention. Records must be "preserved and accessible for up to seven (7) years following the completion of the job."
What makes a digital record inspection-ready
An inspection-ready record is current, searchable on site, locked after signature and tied to a verified signer. BiltOn took part in the DOB pilot that preceded the bulletin, as described in NYC DOB approves digital record keeping. Our GC guide to DOB digital record keeping and the benefits of digitizing safety records cover the rest. The goal is records that stand up to regulators, insurers, and owners.
Where do federal OSHA records overlap with city rules?
City rules sit on top of federal duties. OSHA's 29 CFR 1904 requires covered employers to log recordable injuries and illnesses, and standards such as 1926.503 require written training certification. A GC answers to DOB and OSHA about the same events.
OSHA recordkeeping basics for GCs
Covered employers use OSHA Forms 300, 300A and 301, per OSHA's recordkeeping requirements. All employers must report a work-related death within 8 hours and an in-patient hospitalization, amputation or eye loss within 24 hours. 29 CFR 1926.503 requires a written fall protection training record, and that standard appears on OSHA's preliminary Top 10 most cited standards for fiscal year 2026.
What OSHA asks for during an inspection
OSHA's Field Operations Manual, Chapter 3 points inspectors to the OSHA 300 log and related records. Penalty maximums adjust for inflation each year, so check OSHA's current penalty amounts. See OSHA inspection documentation, construction safety inspection software and why injury logs alone fall short in lagging indicators.
How do compliance records become claims defense?
The time-stamped records that satisfy DOB also defend claims and support renewals. This is the case for leadership: a GC that can show who was on site, what each worker was trained for and what each one signed holds a defensible record.
What a defensible site record looks like
A defensible record is created at the moment of work, tied to a verified person and locked afterward. Facing a fraudulent injury claim on a paper-run project, the Rabsky Group spent more than $35,000 before the claim was dismissed (client-reported), as told in how Rabsky disproved a false injury claim.
What carriers look for
Carriers price the risk they can see. ENR reported in June 2026 that builders' risk insurers are rewarding contractors who demonstrate jobsite risk management with lower deductibles, premium credits and better terms in some cases. SD Builders reports zero fraudulent injury claims in its first year after moving to reduce fraudulent claims (client-reported). See how Triton Construction builds a standard on safety intelligence, plus our guides on claims defensibility and how verified data helps lower workers' comp premiums.
What does a 30-60-90 day compliance plan for NYC GCs look like?
Start with the records that carry the largest penalties, move daily paperwork into a compliant digital system, then report across every site.
Days 1 to 30. Audit WTPA notices and subcontractor payroll paperwork, and check every active worker against Training Connect.
Days 31 to 60. Move Chapter 33 documents and daily logs into a system that meets Buildings Bulletin 2024-007.
Days 61 to 90. Report compliance by site and subcontractor on one dashboard.
Deloitte projects a need for 499,000 new construction workers in 2026, and more than 80 percent of hiring firms tell AGC qualified workers are hard to find. BiltOn works as the verifiable truth layer under Procore and Autodesk; read safety intelligence explained and how teams close the safety data gap for Procore and Autodesk users. Vorea used real-time oversight to cut observation close-out time from 8 days to 4 (client-reported), and Benchmark Builders brought access control built for interiors to sites with no single entrance.
How do you start building audit-ready compliance today?
Pick the record you would struggle to produce tomorrow, whether a subcontractor's pay notices, an SST log or a pre-shift meeting record, and fix that system first. See every site, verify every worker, prove every record. Peers compared notes at the 2026 NY Build panel, and the standard for safety intelligence explains the model.
For Safety Directors. Close the SST log and Chapter 33 gaps first.
For COOs. Report compliance by subcontractor so exceptions surface early.
For CFOs and Risk. See how verified records turn jobsite data into lower insurance costs and why consistent safety platform adoption matters at renewal.
To see how BiltOn keeps every site audit-ready, book a BiltOn demo.
Executive takeaway
NYLL 198-e makes a subcontractor's unpaid wages the GC's liability on covered private contracts.
Missing Chapter 33 documents rank among DOB's top stop work order conditions.
Digital records are allowed only when the system meets Buildings Bulletin 2024-007.
Frequently asked questions
1. What is a wage theft prevention notice?
It is the written pay notice New York employers give each new hire, listing pay rates, basis of pay, payday, employer details and allowances.
2. What does WTPA mean?
WTPA stands for the New York Wage Theft Prevention Act, in effect since April 9, 2011. It requires pay notices at hire and a wage statement with every payment.
3. What languages must the WTPA notice be in?
English plus the employee's primary language when NYS DOL offers a translation: Spanish, Chinese, Haitian Creole, Korean, Polish or Russian.
4. Is a general contractor liable for a subcontractor's unpaid wages in New York?
Yes, on covered private construction contracts. Section 198-e makes the contractor jointly and severally liable for unpaid wages at any subcontractor tier, with exclusions for Article 8 public work and certain residential contracts.
5. What triggers a stop work order in NYC?
Unsafe work or conditions, such as work without a permit, work off approved documents, failure to safeguard and missing Chapter 33 documents.
6. How do you get a stop work order lifted in NYC?
Correct the conditions, file any required Certificate of Correction, pass re-inspection, pay penalties and ask the issuing unit to rescind. Working against an order costs $6,000, then $12,000 for each later offense.
7. Who needs an SST card in NYC?
Workers and supervisors on sites that require a site safety manager, coordinator or superintendent. Workers need 40 hours and supervisors 62, validated in DOB Training Connect before entry.
8. Can NYC site safety records be kept digitally?
Yes, when the system meets Buildings Bulletin 2024-007, including an on-site device, locked time-stamped records and retention for up to seven years.
Works Cited
Associated General Contractors of America. (2026). 2026 construction hiring and business outlook report
Deloitte Insights. (n.d.). 2026 engineering and construction industry outlook
Engineering News-Record. (2026). Insurers offer discounts for using site monitoring tech to reduce risk
Manhattan District Attorney's Office. (2026). D.A. Bragg announces guilty plea in $325K wage theft by School Construction Authority subcontractor
New York City Comptroller. (2023). NYC Comptroller's Office secures $500,000+ settlement from construction firms for wage theft and payroll fraud
New York City Council. (2017). Local Law 157 of 2017
New York City Council. (2017). Local Law 196 of 2017
New York City Department of Buildings. (2022). 2022 NYC Building Code, Chapter 33: Safeguards during construction or demolition
New York City Department of Buildings. (2024). Buildings Bulletin 2024-007
New York City Department of Buildings. (n.d.). Construction safety report 2025
New York City Department of Buildings. (n.d.). DOB violations
New York City Department of Buildings. (n.d.). Guide: Stop work order (SWO) issuance
New York City Department of Buildings. (n.d.). NYC DOB Training Connect
New York City Department of Buildings. (n.d.). Site Safety Training: Frequently asked questions
New York City Department of Buildings. (n.d.). SST worker information
New York City Department of Buildings. (n.d.). Stop work order
New York City Department of Buildings. (n.d.). Stop work order common conditions
New York City Mayor's Office of Operations. (2026). Preliminary Mayor's Management Report 2026: Department of Buildings
New York State Department of Labor. (2023). Guidelines for wage statement provisions (LS 45)
New York State Department of Labor. (n.d.). Notice of pay rate
New York State Department of Labor. (n.d.). Wage theft and labor standards law
New York State Senate. (n.d.). New York Labor Law section 198-E: Construction industry wage theft
New York State Senate. (n.d.). New York Labor Law section 198: Costs, remedies
U.S. Bureau of Labor Statistics. (2026). National census of fatal occupational injuries in 2024
U.S. Occupational Safety and Health Administration. (n.d.). 29 CFR 1904: Recording and reporting occupational injuries and illnesses
U.S. Occupational Safety and Health Administration. (n.d.). 29 CFR 1926.503: Training requirements (fall protection)
U.S. Occupational Safety and Health Administration. (n.d.). Field operations manual, chapter 3: Inspection procedures
U.S. Occupational Safety and Health Administration. (n.d.). Injury and illness recordkeeping and reporting requirements
U.S. Occupational Safety and Health Administration. (2026). OSHA penalties
U.S. Occupational Safety and Health Administration. (2026). Top 10 most frequently cited standards
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