New York Counties Must End Civil Immigration Detention Agreements by November 25

New York is approaching a statutory deadline for local governments and law enforcement agencies to unwind agreements that allow local correctional facilities to house people detained for federal civil immigration violations. On November 6, Governor Kathy Hochul and Attorney General Letitia James announced that the Office of Immigrant Trust (OIT), within the New York State Office of the Attorney General (OAG), had sent guidance to county executives and sheriffs statewide. The law’s November 25, 2026 deadline is 18 days away as of November 7, placing contract review and documentation on an immediate schedule for affected local entities and their service providers.

The Local Cops, Local Crimes Act was signed by Governor Hochul on May 27, 2026. It bars local governments and law enforcement agencies from entering into, modifying, renewing, extending, or remaining in a contract, intergovernmental service agreement, or other formal or informal arrangement to house or detain people for federal civil immigration violations. Agencies with prohibited agreements must use the agreements’ termination provisions by November 25. After that date, covered agreements are void and unenforceable under state law. The act therefore reaches beyond new solicitations or renewals: existing arrangements must also be reviewed and brought into compliance.

For procurement and contract-management teams, the central issue is whether an agreement authorizes detention based solely on a civil immigration violation. The supplied guidance distinguishes those arrangements from contracts involving people facing pending federal criminal charges: criminal-detention services may continue if the agreement does not authorize detention solely for a civil immigration violation. Where an agreement supports both criminal and civil detention, the agency must end the portion permitting civil immigration detention. Local officials and contractors should examine scopes of work, booking and custody procedures, access provisions, payment terms, and termination language to determine whether the prohibited services can be severed or whether the agreement must be terminated.

The compliance exercise has operational and commercial implications for detention operators and other contractors supporting county facilities. Providers may need to identify which services, staffing, facilities, or billing practices relate to civil immigration detention and separate those from permitted criminal-detention work. Counties and sheriffs must also report their compliance steps to OIT—or confirm that they have no prohibited agreements. Attorney General James said, “My office is providing guidance to help local officials understand their obligations under the law and ensure they meet the deadline.” The announcement signals a near-term state compliance priority, but the source does not identify contract values, specific affected counties, or named private vendors.

• Deadline: Counties and sheriffs must end prohibited agreements by November 25, 2026; the deadline is 18 days away as of November 7.
• Covered entities: The law applies to New York local governments and law enforcement agencies, including county governments and sheriffs’ offices.
• Agreement scope: Prohibited arrangements include contracts, intergovernmental service agreements, and other formal or informal agreements to house or detain people for federal civil immigration violations.
• Restricted actions: Agencies may not enter, modify, renew, extend, or remain in covered agreements.
• Mixed-use contracts: Agencies must end the civil-immigration detention portion; criminal-detention services may continue when they do not authorize detention solely for a civil immigration violation.
• Contractor action: Review statements of work, custody practices, access rights, billing, and termination provisions; determine whether prohibited terms can be severed or require termination.
• Compliance reporting: Counties and sheriffs must report their compliance steps to the Office of Immigrant Trust or confirm that no prohibited agreements exist.
• Enforcement effect: After November 25, prohibited agreements are void and unenforceable under state law.
• Guidance and announcement: OIT, within the New York State Office of the Attorney General, sent guidance to county executives and sheriffs; Governor Kathy Hochul and Attorney General Letitia James announced the action on November 6.