485X / Sep 9, 2026
99 vs. 100 units: the 485-x threshold developers should model early
Why a single apartment can change the affordability and labor framework of a New York rental development.
In ordinary design work, the move from 99 to 100 apartments may look incremental. Under 485-x it can be a category change.
At 99 units
A qualifying rental project can fit the modest-rental Option B framework: 6–99 units, 20% affordable housing units, average 80% AMI and a 35-year benefit, subject to the full eligibility requirements.
At 100 units
A qualifying project moves into the large-rental Option A framework. The affordable share generally increases to 25%, the average AMI remains 80% for the large-project profile, and applicable construction work becomes subject to the statutory 485-x wage requirements.
The correct comparison is not “one more unit”
A serious model should compare revenue, affordable-unit count, hard-cost labor assumptions, financing, tax benefits, construction duration and operational obligations under each design. The correct answer depends on the site and may not be the same for every project.
For 2026, the NYC Comptroller publishes a $42.03 hourly minimum for the applicable 100+ unit construction category, with separate Zone A/B formulas for qualifying very-large projects.