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Vermont lead rules for rentals: IRC Practices and the yearly compliance statement

Short answer: Every Vermont rental built before 1978 falls under IRC Practices (called Essential Maintenance Practices, or EMPs, before October 2022). Someone with the short IRC training inspects and cleans every year and at each new tenant, peeling paint is fixed within 30 days, and you file a compliance statement with the Health Department within 365 days of your last one, then give copies to your insurance carrier and an adult in each unit. Filing is free.
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Who it covers

Every rental unit built before 1978, of any size, anywhere in Vermont. An IRC-certified person must inspect and clean each year and at each new tenant, licensed workers must fix peeling paint within 30 days, and the owner files a compliance statement with the Health Department every 365 days and gives copies to tenants and the insurance carrier. EMPs were renamed IRC Practices when new rules took effect in October 2022.

How long it lasts

Compliance statement: 365 days from when the last one was received. IRC training certificate: 5 years.

What it costs

Filing is free. The IRC course takes about 2–3 hours. Paint repairs over 1 square foot per room need a Lead-Safe RRPM licensed worker.

If you don’t comply

Administrative penalty up to $5,000 per violation; each day a violation continues after notice can count separately (18 V.S.A. § 1766). Filing a false compliance statement is fraud and removes your liability protection. An older Health Department EMP filing FAQ listed $50 for filing within 30 days after the due date and $150 for later (current amounts not confirmed). Buyers of non-compliant rentals have 60 days after closing to comply or face a mandatory penalty.

What you need and when

What you needWhenCost
IRC Practices Compliance Statement
Due no later than 365 days after your last statement was received (a rolling date, not a fixed calendar day); a new owner must file within 60 days of closing if none was filed in the past 12 months. File online, then give a copy to your liability insurance carrier and an adult in each unit every year. Statements can only be filed early, which resets the due date. Ask for an extension at least 10 days before the due date (30 days for most work; up to 6 months for exterior repairs found in winter).		every 365 daysFree to file online.
IRC inspection and specialized cleaning
At least yearly and at each change of tenant: inspect inside and out for chipping or peeling paint, pick up paint chips, block access to damaged areas right away, have a Lead-Safe RRPM licensed worker repair more than 1 square foot per room or exterior side within 30 days, confirm window well inserts in all pre-1978 wooden sash windows, specialized cleaning of common areas yearly and of a unit at each new tenant, and keep a posted notice asking tenants to report deteriorated paint.		every year; before each new tenant moves inDo it yourself after IRC training, or hire a Lead-Safe RRPM firm.
Tenant lead packet before lease
Before the lease starts: 'Protect Your Family From Lead in Your Home' pamphlet, a copy of the unit's most recent IRC compliance statement, and any known lead information. Federal EPA/HUD disclosure applies too.		before each new tenant moves in-
IRC Practices certificate (person doing the work)
Course is online or in person; the Health Department's training page says about 2 hours, another of its PDFs says about 3 hours. Pass with 70%+. Certificate valid 5 years; old EMP certificates more than 5 years old had to be renewed starting October 1, 2022.		every 5 years-

Not covered

Certificate types

How to get inspected

An IRC-certified person (the owner after the short course, staff, or a Lead-Safe RRPM firm). Paint repairs over 1 sq ft per room/side need Lead-Safe RRPM licensed workers (a Lead-Safe RRPM Firm - Landlord license lets owners do it). Lead-free exemption needs a Vermont-licensed lead inspector or risk assessor.

What to give tenants

The federal lead disclosure rule applies on top of this for nearly every rental built before 1978. What it requires.

Where to register or file

IRC Practices Compliance Statement Service: Online portal, free; anyone can search statements filed in the past 365 days without an account

Where sources disagree: (1) Training length: the user brief said a 4-hour EMP class; current Health Department training page says the IRC course and test take about 2 hours, while its 'How to Comply' PDF says about 3 hours (healthvermont.gov vs healthvermont.gov). Use 'about 2-3 hours'. (2) Repair threshold: statute 18 V.S.A. § 1751 defines minor RRPM as under 1 sq ft interior or 20 sq ft or less exterior, but the Health Department IRC page says more than 1 square foot per interior room or exterior side needs a licensed worker. We show the stricter Health Department version. (3) Dates: the IRC course manual says the new regulations took effect 10/1/2022; statute amendments are marked effective 2022-10-21; the EMP law itself dates to 1996.

Keep every certificate on time

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Questions landlords ask

When is the Vermont lead compliance statement due?

Every 365 days from the date your last statement was received. There is no single statewide due date; new owners must file within 60 days of closing if no statement was filed in the past year.

Are Vermont EMPs still required?

Yes, under a new name. Since October 2022 they are called Inspection, Repair and Cleaning (IRC) Practices; most steps are the same, but repairs over 1 square foot now need a Lead-Safe RRPM licensed worker.

Who gets a copy of my Vermont IRC compliance statement?

File it with the Health Department online, then give a copy to your liability insurance carrier and an adult in each unit every year. New tenants also get the latest statement before their lease starts.

How long is the Vermont IRC training?

About 2 to 3 hours including the test, online or in person. The certificate lasts 5 years.

What is the penalty for not filing in Vermont?

The Health Department can fine up to $5,000 per violation, and each day can count after notice. Staying compliant also gives you protection from habitability lawsuits over lead under 18 V.S.A. § 1761.

Can a Vermont rental be exempt from IRC Practices?

Yes, if a Vermont-licensed lead inspector tests the building with XRF or lab paint samples, finds no lead-based paint, and the Health Department approves an exemption. Home test swabs do not count.

Last checked November 6, 2026. Law: 18 V.S.A. ch. 38 (§ 1759 RRPM activities, § 1761 liability, § 1766 penalties, § 1767 transfers); Vermont Regulations for Lead Control. Agency: Vermont Department of Health, Asbestos and Lead Regulatory Program.

This page sums up published rules as of November 6, 2026. It is not legal advice, and myleadsafe is not a government site. Rules and fees change, and local offices add their own steps, so confirm with your town or city and the state agency before you rely on a date or a fee.

Sources (14)