The Hard Math Behind Any New York City Rent Freeze

With Mayor Zohran Mamdani’s calls to “reset” New York City’s housing policy to enhance affordability, one question looms large over the next rent cycle: Will there be a rent freeze in 2026? The answer lies with the Rent Guidelines Board (RGB) and whether Mamdani can attain five votes by June, when the final vote will take place.   

The RGB is the nine-member body that sets annual rent increases for New York City’s rent-controlled housing. Its members are appointed by the mayor but intentionally pluralistic: two tenant members, two owner members and five public members, including the chair. Members serve staggered terms and may continue as holdovers after their terms expire until successors are appointed. 

In March 2025, the Adams administration appointed a new chair, and added public members. Reports toward year end suggested City Hall was weighing additional appointments and reappointments to fill expired or vacant seats before the current administration’s clock ran out. As anticipated, shortly before the new year, the Adams administration did, in fact, announce four appointments and reappointments to the RGB, all of which were spread across the tenant, owner and public member spread.

The historic voting record reflects the present balance: On June 30, 2025, the RGB approved increases of up to 3 percent for one-year leases and 4.5 percent for two-year ones, respectively, by a 5-4 margin, signaling a board that did not coalesce around a freeze.

Legally, a rent freeze is not a mayoral order — it is a majority vote of the RGB. Five votes are needed. While the incoming mayor can replace the chair, he cannot immediately rewrite the membership mix unless vacancies or expirations exist. Holdover rules mean incumbents do not roll off automatically. Instead, they need to be driven out. Therefore, the path to five votes runs through composition and political persuasion. 

Based on the late-term appointments by the Adams administration, Mamdani may have inherited a board that seeks some level of rent increase. The determination depends upon a three-pronged analysis: (1) identifying vacancies to fill with aligned public members (and one of Adams’s late December appoints did decline to accept the position); (2) building a data-forward case — on why a rent freeze would benefit housing — to attract one or two current public members; and (3) encouraging holdovers to withdraw so that Mamdani can populate the board with his administration’s handpicked selections. 

The arithmetic is unforgiving. A freeze most plausibly requires tenant members plus at least three public members. If the public bloc stays divided, the votes are not there, nixing any rent freeze in 2026. 

The chair serves at the pleasure of the mayor. That matters because the chair sets agendas, shapes hearings, steers staff analysis, and can often be the swing among public members. A new chair aligned with a freeze can recalibrate the process — emphasizing affordability, reweighting operating income and expense trends, and reframing vacancy data. None of that guarantees votes but increases persuasion.

At the same time, RGB independence is not cosmetic. Members will need to weigh operating costs, incomes, affordability and housing stability — not merely ratify City Hall’s policy by fiat.

Owner representatives will invariably argue that insurance, taxes and compliance costs outstrip recent increases, and that a freeze accelerates capital disinvestment. Tenant representatives will stress rent burdens and stagnant wages. The public swing members will look for a framework that guards against both rent shock and deterioration of the housing stock. If the Mamdani administration produces credible, transparent analysis — and reinforces it with real data figures, together with proper messaging — the five-vote coalition becomes plausible.

Owners, then, should plan for potential rent freeze scenarios: Model cash flow under a freeze and under slim increases; prioritize life-safety and mandated work; document rising cost drivers to inform the record. For tenants and advocates, anchor the case in data showing rent burdens, arrears trajectories and neighborhood‑level impacts. 

A 2026 rent freeze is strategically achievable but certainly not guaranteed. The RGB’s five‑vote threshold, staggered membership and holdover rules temper electoral change, and late‑term appointments may further produce a filibuster. While day one of Mamdani’s reign brings an immediate chair replacement and a reset of process and priorities, it does not bring a guaranteed fifth vote. If not, there will most likely be a modest increase per recent historical trends and a longer game for Mamdani to reconstitute the board for the following cycle to position for a 2027 rent freeze.

Massimo F. D’Angelo is a partner at Blank Rome and co-chair of the firm’s real estate industry group. William M. Pekarsky is an associate at the firm.