Free SB 1103 checklist before you charge costs.
Before a landlord charges a qualified commercial tenant for building operating costs, SB 1103 asks for documentation. Check the packet item by item, and work out the dates that go with it.
The dates
Documentation due by
Wednesday, April 1, 2026
Within 30 days of a written request, and no operating cost fee until it is provided. Civil Code 1950.9
The 18-month window
Outside the 18 months
Inside the window
Our readingFor a charge on July 2, 2026, costs count from January 2, 2025, or are expected by July 2, 2027. Ask counsel before relying on it.
What goes in the packet
A checklist from the statute's text, checked October 25, 2026. Not legal advice; talk to a California attorney about your situation.
What the statute says
A landlord may not charge a qualified commercial tenant a fee to recover building operating costs unless all six of these hold.[1]
Costs are allocated proportionately per tenant, by square footage or another method backed by documentation given to the tenant.[1]
Costs were incurred within the previous 18 months, or are reasonably expected within the next 12 months based on reasonable estimates.[1]
Before the lease was signed, the landlord gave notice, on paper or electronically, that the tenant may inspect supporting documentation on written request.[1]
Within 30 days of a written request, the landlord provides the supporting documentation.[1]
Costs exclude expenses the tenant paid directly to a third party.[1]
Costs exclude expenses reimbursed by a third party, a tenant or insurance.[1]
No such fee may be charged until the landlord provides the supporting documentation (1950.9(b)).[1]
The allocation method may not change during the tenancy in a way that raises the tenant's share without written notice and documentation (1950.9(c)).[1]
Supporting documentation means a dated, itemized quote, contract, receipt or invoice from a licensed contractor or service provider, with a tabulation of how costs are allocated among tenants and a signed, dated landlord attestation that the documentation and costs are true and correct (1950.9(h)(6)).[1]
These rules cover leases executed, and tenancies commenced or renewed, on or after January 1, 2025; week-to-week, month-to-month and shorter periodic tenancies; and earlier leases with no building operating cost provision. They don't apply to property and business improvement district assessments (1950.9(i) and (j)).[1]
Our readingFor a calendar-year reconciliation, January's costs pass the 18-month mark around July 1 of the next year, so an owner with qualified commercial tenants would deliver the reconciliation and its documentation by about June 30. Ask counsel before relying on that date.[1]
The backup this law asks for, kept with each line.
Cornerhold traces each CAM line to its invoice and lease clause, which is the kind of backup SB 1103 asks a landlord to provide. It doesn't yet track qualified commercial tenant status, the 18-month window or the 30-day clock; keep those with this toolkit for now.
Checked October 2026 against official sources
Each statement above links to the official page it comes from. We read every one on October 25, 2026.
- 1Civil Code 1950.9
Building operating costs charged to a qualified commercial tenant (SB 1103).
leginfo.legislature.ca.gov, checked October 25, 2026
Change log
- October 23, 2026First version, checked against the official text.
- October 25, 2026Checked again against the official text. Added 827(c) on longer notice periods, a question on when a fixed-term tenant first gave notice, and a caution for tenants close to a year of occupancy.
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