SB 1103 CAM Compliance: What California Landlords Must Have Ready Before a Tenant Asks

Updated: February 2026 · For controllers and property managers at California commercial PMCs

1. What SB 1103 Actually Requires

The Qualified Commercial Tenant Definition

SB 1103 protections apply only to Qualified Commercial Tenants (QCTs). A tenant qualifies under one of three categories:

• Microenterprise: A commercial tenant that qualifies as a microenterprise under Business & Professions Code §18000(a) — meaning it has five or fewer employees, including the owner
• Restaurant: A food service business with fewer than ten employees
• Nonprofit: An organization holding §501(c)(3) status with fewer than twenty employees

Self-attestation requirement: Under Civil Code §1950.9(a), a tenant establishes QCT status by providing a written self-attestation. Once a landlord receives that attestation, all SB 1103 protections activate for that tenancy. Landlords cannot challenge the attestation absent evidence of fraud.

Statutory Provisions in Play

SB 1103 amended or added four Civil Code provisions:

• Civil Code §1950.9: The primary new provision. Establishes CAM documentation production obligations and the 30-day deadline. Requires itemized primary-source invoices, explicit allocation methodology, and a signed landlord attestation.
• Civil Code §827: Restricts rent increases for QCT tenants to one increase per 12-month period. Requires 90 days' advance written notice for any increase exceeding 10% of the lowest rent charged in the prior 12 months.
• Civil Code §1632: Language access requirement. If a commercial lease was negotiated primarily in Spanish, Chinese, Tagalog, Vietnamese, or Korean, the landlord must provide a written translation before execution.
• Civil Code §1946.1: Restricts automatic renewal. For QCT tenants with leases of 12 months or more, termination requires 60 days' written notice. Continued rent acceptance after lease expiration triggers month-to-month continuation under QCT protections.

2. The 30-Day Clock

What Triggers It

Under Civil Code §1950.9, the 30-day production clock starts when a QCT submits any written request for CAM documentation. An email asking for “the invoices behind our CAM charges” qualifies. A text message asking for “the reconciliation backup” qualifies. The trigger is a written request — not a formal legal demand.

Once the clock starts, it cannot be stopped by offering a partial production or claiming the documents are being assembled.

What Must Be Produced Within 30 Days

Civil Code §1950.9 specifies three mandatory components. All three must be present:

1. Itemized primary-source invoices from licensed contractors: Summary ledgers and management system printouts do not satisfy this requirement. The law requires the actual invoices — line-itemized, from the vendor or contractor, showing the property address, work description, and amount charged.
2. Explicit allocation tabulation showing numerator and denominator: The documentation must show the pro-rata calculation: the tenant's rentable square footage as numerator, the total rentable square footage (or contractual denominator) as denominator — for each expense line.
3. Signed landlord attestation: A written attestation, signed by the landlord or an authorized representative, confirming that the documented expenses are accurate and the allocation methodology conforms to the lease. Unsigned boilerplate does not satisfy this requirement.

Temporal Scope

• 18 months retrospectively: A QCT tenant can request documentation for CAM charges assessed up to 18 months before the written request date.
• 12 months prospectively: If a QCT tenant requests projected CAM estimates, the landlord must provide the projected allocation for the 12-month period following the request.

3. The 5 Documentation Gaps That Create Liability

4. How to Achieve Compliance Before a Tenant Asks

The five steps below create a defensible compliance position before any request arrives.

1. Audit every current lease for QCT status. Pull your full tenant roster and send written self-attestation forms to every commercial tenant with 20 or fewer employees. Annotate each lease file with the attestation receipt date — this establishes when protections became active.
2. Add pre-execution notice to all new leases. Draft a one-page QCT Rights Notice modeled on Civil Code §1950.9 language. Require tenants to sign it as a lease exhibit before execution. This eliminates Gap 1 for all new leases.
3. Digitize and attach invoices real-time to tenant ledger. Every vendor invoice for a QCT-occupied property must be received in original PDF form, tagged to the property and expense period, and stored for retrieval by tenant and date range. Year-end batch collection will not produce a compliant 30-day response.
4. Build the 30-day production kit. Prepare a template production package for each QCT-occupied property: invoices organized by month and GL category, a pre-formatted allocation matrix template, and a signed attestation template awaiting only the current date. When a request arrives, production should take hours — not weeks.
5. Set calendar alerts for statutory notice deadlines. 90-day alerts before any planned rent increase exceeding 10% (Civil Code §827); 60-day alerts before lease expiration (Civil Code §1946.1); 30-day production target for any CAM documentation request.

Frequently Asked Questions

Does SB 1103 apply to all California commercial leases?

No. SB 1103 protections apply only to Qualified Commercial Tenants — defined as microenterprises with 5 or fewer employees (including the owner) under B&P §18000(a), restaurants with fewer than 10 employees, and §501(c)(3) nonprofits with fewer than 20 employees. Standard commercial tenants — corporations, partnerships, larger businesses — are not covered.

What happens if we miss the 30-day production deadline?

Civil Code §1950.9 creates a private right of action for QCT tenants who do not receive compliant documentation within 30 days of a written request. Courts may award actual damages, statutory damages, and attorney's fees. The treble damages provision applies if the court finds the landlord's non-compliance was willful. Missing the deadline once can generate liability exceeding the total CAM charges in dispute.

Can a tenant self-certify QCT status or do we need to verify it?

The law allows self-attestation: the tenant provides a signed written statement confirming they meet the headcount threshold. You are not required to independently verify the attestation. However, once you receive a signed attestation and act on it as though the tenant qualifies, you cannot later deny QCT protections to that tenant without evidence of fraud in the attestation.

Are property management companies considered the "landlord" for purposes of Civil Code §1950.9?

Yes. A property management company acting as the landlord's authorized representative bears the same obligations as the property owner. The 30-day clock runs against whoever controls the documentation and bills the CAM charges. Property managers who do not have primary-source invoice retention procedures in place are personally exposed — and their clients are as well.

Do the SB 1103 provisions apply to leases signed before January 1, 2025?

Yes. The documentation production obligations, notice requirements, and rent increase notice requirements apply to existing QCT tenancies, not just new leases. The only provision that applies only prospectively is the pre-execution notice requirement — you cannot retroactively provide a notice that was due before signing. But all other obligations apply to current QCT tenants regardless of when the lease was signed.