NY S02520

Establishes that failure to acknowledge a FOIL request within five business days constitutes a denial that can be appealed

Creates phased maximum deadlines for agencies to provide records once a request is granted: 180 days for requests before December 31, 2026; 90 days for requests in 2027; and 60 days for requests starting January 1, 2028

Allows agencies to exceed these deadlines only under specific conditions: federal law prevents compliance, employees cannot safely access records, or the volume of records makes timely review unreasonable

Requires agencies claiming an exception to notify both the requestor and the Committee on Open Government in writing, with detailed explanations signed by the agency commissioner and monthly progress updates to the requestor

Takes effect January 1, 2026