State law covering ESAs in housingN.Y. Exec. Law § 296(18) — state human rights law — reasonable accommodation in housingYes
Effect of HUD's May 2026 changeState-law route is independent of HUD enforcementLimited
Minimum client–provider relationshipNo statutory waiting period in New YorkNone
Pet fees and deposits for an approved ESAAddressed by state law, independently of HUDState law
Penalty for false documentationNo ESA-specific penalty statute; general fraud and misrepresentation law still appliesGeneral law
Public access rights for ESAsIn New York or any state — that is a trained-service-animal right under the ADANone
Where a complaint goesNew York State Division of Human Rights; NYC Commission on Human RightsNYSDHR