Self-Certification with DOB – Overview, Process, Risks, and Benefits

Building on the earlier discussion of when to self-certify (Topic 5), here we provide a comprehensive overview of NYC’s self-certification process itself – known formally as the Professional Certification program – including how it works, what a business owner should know about it, and its pros and cons in general.

What is the DOB Professional Certification Program?

The NYC Department of Buildings’ Professional Certification (Pro Cert) program allows licensed design professionals (Professional Engineers or Registered Architects) to certify that their plans conform to code and zoning without a DOB plan examiner reviewing them. In practice, this means a quicker approval for permits. The architect/engineer takes on the responsibility for compliance, and the DOB trusts their sign-off, subject to audits. This is an alternative to the standard DOB Full Plan Review where a DOB examiner must approve the plans.

Key points from DOB about how Pro Cert works:

The decision to use Professional Cert must be made when filing the job initially (at pre-filing).
The filing process (applications, forms, fees) is the same up until the plan review stage. If all required documents are submitted, a professionally certified application will be approved at the end of data entry, meaning essentially immediately once the paperwork is deemed complete.
No plan examiner review happens, so the applicant can go straight to pulling a permit after approval.
Importantly, all Post-Approval Amendments (changes to the plan after initial approval) on a self-certified job must also be self-certified. You can’t switch to DOB review mid-stream unless you withdraw and refile, generally.
DOB conducts audits on a percentage of these jobs. For example, once the first permit is pulled, a certain percent of filings are selected for audit. Also, random audits can occur. If an audit finds issues, DOB can revoke the permit and require corrections, and they can take action against the professional.

Benefits of the Self-Cert (Pro Cert) Process:

Speed to Permit: As highlighted, the biggest win is speed. You cut out waiting for a DOB plan examination appointment and review cycle. If time = money (which it does in NYC), getting that permit perhaps months earlier can save on carrying costs, rent, etc. DOB itself states that Pro Cert “reduces the amount of time a builder normally has to wait for a DOB permit” by eliminating plan examination.
Control: The design team can finalize and file plans on their own schedule. Under normal process, you might file and then sit idle waiting for comments. With self-cert, if the plans are ready, you file and move on. This is great for fast-track projects.
One Less Hurdle: Sometimes dealing with plan examiners adds uncertainty – different examiners might have slightly different interpretations. Self-cert avoids that inconsistency; the onus is on one party (your architect) to get it right.
Ideal for Certain Work Types: Many Alteration Type 2 filings (non-major alterations) and straightforward jobs (like interior renovations that don’t change use or exits) are commonly self-certified. Also, things like facade repairs, typical storefront alterations, etc., are often self-certifiable. It’s become a normal part of doing business for many NYC architects on small to mid-size projects.

Risks and Oversight in the Process:

Audits and Violations: As mentioned, the DOB will audit some self-certified jobs. If your architect took a shortcut or missed something, an audit could catch it. Worst-case scenario, if a serious violation is found, work might need to pause. However, typically audits might result in requiring submission of revised plans to correct any non-compliance. It’s a risk to be aware of – even after you start work under a permit, you’re not 100% in the clear until the statute of limitations for audit passes (which might be when the job sign-off occurs or a set time after permit issuance).
Dependence on Professional’s Integrity: The system assumes the professionals are doing the right thing. Most do, because the consequences are high – the DOB can strip an architect or engineer of their self-cert privileges if they abuse it. In fact, over the years, DOB has disciplined some who self-certified jobs with multiple code issues. So you want a professional with a good track record.
No DOB Guidance: If you’re uncertain about some code requirements, in a full plan review you could discuss with the DOB examiner or get an official determination on a gray area. In self-cert, you’re essentially asserting everything is fine, and hoping DOB sees it the same way. If you anticipate a tricky code interpretation, some architects actually avoid self-cert in that case to get DOB on record with approval.

Recent Updates and Considerations:

NYC has tweaked the self-cert program over time. There are checks to prevent abuse:

Certain job types or larger projects may be ineligible for self-cert (DOB often limits Pro Cert for things like new buildings, certain special district rezonings, etc., to maintain oversight).
Local Law 108 of 2019 (which is referenced on DOB’s site) added requirements for increased integrity in the program – this law was passed after some incidents of improper self-certification, to ensure accountability. It mandates, among other things, that DOB publish reports on who’s self-certifying and audit results, adding transparency.
There’s also a Directive 14 in NYC (a related but distinct program) which is another form of limited review, sometimes conflated with self-cert. Under Directive 14, DOB does a cursory review focusing on life safety and skips some detailed checks, relying on the professional for those. It’s different from full self-cert but also aimed at speeding up jobs. Your architect will choose the right filing method (Directive 14 vs Pro Cert vs Full Plan Exam) depending on the project specifics.

For Business Owners – Practical Takeaways:

When hiring an architect, you might ask if they plan to professionally certify the project. If they say yes, it’s worth asking, “Do you anticipate any issues with an audit? Have you done similar self-cert projects that went smoothly?” A confident, experienced architect will have answers (and likely a good track record).
Don’t pressure an architect to self-certify if they advise against it. If they say, “We should go through plan exam because XYZ,” they likely have a good reason – maybe the design is pushing some envelopes and they want DOB’s eyes on it to be safe.
From your end, make sure all other requirements are aligned. For example, if you’re fast-tracking a permit via self-cert, ensure your other paperwork like landlord approvals or landmark approvals (if in a historic district) are also expedited. Self-cert doesn’t bypass those separate approvals.
Once the project is permitted and underway, ensure your team continues to follow the plans exactly. If an audit happens, the best outcome is that the built work matches the filed plans and all is in order. Changes in the field should be properly documented and amended (self-certified amendments, as required).

In Summary

NYC’s self-certification process is a trade-off: speed and efficiency in exchange for assuming the responsibility of compliance. The system can work beautifully – many projects get permitted in a fraction of the time, keeping NYC’s construction moving briskly. But it relies on the diligence and honesty of professionals. For business owners, the best approach is to work with trusted, experienced architects/engineers who won’t cut corners. When used appropriately, self-certification is a win-win: you get your project done faster, and the DOB can allocate resources to scrutinize more complex projects. Just remember that “faster” doesn’t mean “easier” on compliance – all rules still apply, only the checking of those rules shifts from the city to your hired professional. Contact Parkbench Architects for more information!