New York’s ex-transit chief may have violated state ethics laws by leading a $12.5 billion bid to reconstruct and operate Penn Station, government watchdogs say.

Pat Foye, the former MTA chairman, now consults for Italian transportation conglomerate ASTM, which has jumped into the design competition with a plan that would net Madison Square Garden a $500 million payout, a proposal that the arena helped along by providing engineering assistance.

“He was a powerful person in a very powerful position in state government, now he’s on the outside trying to help his new employer get business with the state,” said Blair Horner, the head of the good government watchdog New York Public Interest Research Group.

Horner and two other ethics experts said that Foye’s activities appeared to run afoul of conflict-of-interest protections unless the ex-MTA honcho obtained a waiver from the state’s ethics enforcer or the Commission on Ethics and Lobbying in Government.

Representatives for Foye refused to say if he obtained a waiver and argued the rules did not apply because the MTA does not technically own Penn Station.

“Any suggestion that he has violated ethical standards is at war with facts and the law as we know them,” said Foye’s attorney, William Wachtel.

“Penn Station is owned by Amtrak, and as such, any revitalization plans will be determined by Amtrak in partnership with New York, New Jersey, and the federal government,” he added.

Federal records show the MTA is leading the charge on Penn’s reconstruction in partnership with Amtrak and NJ Transit, putting Foye’s former agency at the heart of the fight.

“Given that Penn Station’s redesign is being led by the MTA, a state authority, the state’s ethics commission is the appropriate body to give guidance about the state’s revolving door rules for ongoing work on this major project,” said Rachael Fauss, a top expert on government contracting at the watchdog group, Reinvent Albany.