CAM Reconciliation Deadlines: What the Industry Expects and What the Law Requires
Quick Answer
Industry standard requires delivery within 90 to 120 days after fiscal year-end. California SB 1103 mandates a 30-day window to produce supporting documentation once a qualifying tenant requests it. Missing either deadline can permanently forfeit the right to collect the balance owed.
Timeline at a Glance
| Milestone | Timing | |---|---| | Set new year budget estimates | 30-60 days before lease year start | | Year-end GL scrub | November to December | | Deliver reconciliation statements | Within 90-120 days post year-end | | Tenant objection window | 30 days from receipt (typical lease language) | | SB 1103 documentation response (CA) | 30 days from written request | | Maximum lookback, California | 18 months (SB 1103 hard limit) | | Maximum lookback, other states | 24-36 months (statutory limitation) |
The Standard Delivery Timeline
The industry norm for CAM reconciliation delivery is 90 to 120 days after the close of the fiscal or calendar year. For a December 31 year-end, that means statements go out between March 31 and April 30. CREModels and RE BackOffice both cite this range as the accepted standard across office, retail, and industrial leases.
Most leases codify this in the reconciliation clause. A clause might read: "Landlord shall deliver the annual reconciliation statement no later than 120 days after the close of each lease year." That language is a contractual obligation, not a guideline.
Before year-end, landlords typically set budget estimates for the coming lease year 30 to 60 days before the new year begins. Tenants use these estimates for their own financial planning, and late or missing estimates are themselves a source of friction.
Once the statement goes out, tenants generally have 30 days to object, per standard lease language. The audit window is wider: most leases set it at 30 to 180 days from statement receipt, though underlying statutes in most states allow tenants to look back 24 to 36 months. A tenant who received a statement in April 2024 and signed a lease with a 36-month audit window could still formally dispute that statement in early 2027.
Cushman and Wakefield's property management standards reflect this framework: reconciliations are expected by the end of Q1, disputes are expected to follow within one to two months, and documentation packages should be ready before the first statement goes out.
California SB 1103 Deadlines
New California Requirements
SB 1103 took effect January 1, 2025. If you have qualifying small-business tenants in California, three specific obligations now apply: a pre-lease disclosure, a 30-day documentation production window, and an 18-month hard cap on retroactive billing.
California Civil Code Section 1950.9, enacted by SB 1103, adds statutory deadlines on top of whatever the lease says. For leases with qualifying small-business tenants, three obligations apply.
Pre-lease disclosure. Before the lease is executed, the landlord must provide written notice informing the tenant of their right to request itemized CAM documentation. This is a standalone notice requirement, separate from any lease clause.
30-day documentation window. Once a qualifying tenant submits a written request for supporting documentation, the landlord has 30 days to produce itemized invoices, vendor quotes, and allocation tabulations. No grace period applies. A landlord who cannot produce documentation within 30 days is in statutory violation, regardless of what the lease's audit rights clause says about timing.
18-month lookback limit. A landlord cannot bill a qualifying tenant for any expense incurred more than 18 months before the billing date. This overrides lease language that would allow longer lookback periods. It also means a December 2023 expense cannot be billed to a qualifying tenant after June 2025, even if the lease allows retroactive charges.
Analysis from CalLawyers.org, Allen Matkins, and Perkins Coie all confirm that SB 1103 applies to new leases executed after January 1, 2025, with the documentation and billing provisions affecting existing qualifying leases as well. The full compliance checklist is at /resources/sb-1103-compliance.
What Happens When You Miss the Deadline
Missing the delivery window creates two categories of risk: financial and relational.
On the financial side, stale CAM charges fall outside the lookback window and become permanently uncollectable. Holland and Knight's analysis of stale CAM charges documents this clearly: once an expense falls outside the lease's billing window, no court will enforce it. The landlord absorbs the shortfall with no mechanism for late recovery.
The relational risk compounds over time. IREM Oregon data shows that delayed statements directly correlate with higher tenant dispute rates. When tenants have already closed their books for the year, a late reconciliation arrives as a surprise rather than an expected true-up. Surprises generate pushback, pushback turns into formal disputes, and formal disputes generate legal fees and documentation costs that often exceed the original balance owed.
A single missed deadline can also create a pattern problem. If one year's statement goes out late, tenants with sophisticated property management teams will flag the property as a dispute risk in subsequent years, even when later statements arrive on time.
How to Build a Timeline That Works
Q3: Audit the rent roll for mid-year changes
Pull every lease amendment, expansion, contraction, and move-out dated between January and September. Time-weighted SF adjustments must be in place before the year-end GL closes. A tenant who moved in July gets billed for roughly half a year; using full-year SF on that tenant is a calculable error. Do this in Q3, before year-end pressure makes it easy to skip.
Q4: Begin GL scrub and flag non-recoverable items
Start the general ledger review in November. Look for CapEx coded to operating accounts, management fee structures that need verification, and December invoices that may not post until January. Flag every account as recoverable, non-recoverable, or uncertain. Uncertain items need a lease clause citation before year-end closes. Running this in Q4 leaves time to chase straggler invoices without missing the AP cutoff.
January: Finalize GL and run the reconciliation
With the year-end GL closed, run the full reconciliation: gross-up on variable expenses only, pro-rata denominator confirmed against the BOMA standard in each lease, cap structures applied in the correct sequence. January is the time to catch formula errors before any statement goes out. A reconciliation that passes all validation checks in January can be reviewed and approved in February without pressure.
February: Review and send statements
Send statements in February for a December 31 year-end. This puts delivery well within the 90-day window and gives you a 30-day buffer before the 120-day outer limit. Include the supporting documentation package with each statement: the GL with chart of accounts, gross-up calculation, and pro-rata share summary. Sending documentation proactively reduces inbound questions and shortens the tenant objection cycle. For the complete pre-send review process, see the CAM pre-send checklist.
Stop Tracking Deadlines in Spreadsheets
CAMAudit flags billing window deadlines, tracks outstanding statements by tenant, and generates documentation packages on demand. Upload your GL export and lease abstracts to get started.
Hit Your DeadlinesFrequently Asked Questions
When must CAM reconciliation statements be delivered?
Industry practice requires delivery within 90 to 120 days after the close of the fiscal or calendar year. Most leases reinforce this with an explicit reconciliation clause that sets a hard deadline, commonly March 31 or April 30 for a December 31 year-end. Missing that window does not automatically void the charges, but tenants gain grounds to dispute, and in some states the landlord forfeits the right to collect any true-up balance.
What happens if a landlord delivers the CAM reconciliation late?
The consequences range from losing the right to collect a true-up balance to triggering a formal tenant audit. Many leases include a provision stating that charges not billed within a set period are waived. Even without such a clause, late delivery correlates with higher dispute rates. IREM Oregon data shows that delayed statements directly produce more tenant objections, partly because tenants have already closed their own books for the period.
What is California SB 1103's deadline for CAM documentation?
SB 1103 (Civil Code Section 1950.9, effective January 1, 2025) requires landlords to produce itemized invoices, quotes, and allocation tabulations within 30 days of a written request from a qualifying small-business tenant. The landlord must also notify the tenant of these documentation rights before lease execution. Failure to comply within the 30-day window can result in the tenant withholding disputed charges without penalty under the statute.
How far back can a tenant audit CAM charges?
It depends on the jurisdiction and the lease. Most commercial leases set a contractual audit window of 30 to 180 days from statement delivery. General statutes of limitation in most states extend the lookback to 24 to 36 months. California SB 1103 adds a hard 18-month cap: a landlord cannot charge a qualifying tenant for any expense incurred more than 18 months before billing, regardless of what the lease says.