SB 1103 CAM Disclosure Guide for California Commercial Landlords
California SB 1103 (Cal. Civil Code §827.1), effective January 1, 2025, imposes itemized CAM disclosure obligations on commercial landlords with qualified commercial tenants. This guide explains exactly who qualifies, what must be disclosed, when, and the penalty structure for non-compliance.
By Angel Campa, Founder, CapVeri · Updated April 2026
Legal note: This guide is for informational purposes only and does not constitute legal advice. SB 1103 compliance involves fact-specific determinations; consult qualified California real estate counsel for guidance on your specific lease portfolio.
Quick Answer
SB 1103 (Cal. Civil Code §827.1) requires California commercial landlords to provide itemized CAM disclosures to qualified commercial tenants — those meeting ALL THREE conditions: (1) annual gross receipts of $250 million or less, (2) leasing 10,000 SF or less, AND (3) in a building of 100,000 SF or less. Initial disclosure is due within 90 days of lease commencement; annual disclosure within 90 days of the reconciliation period end.
Who Is a "Qualified Commercial Tenant"?
The SB 1103 disclosure obligations — and the treble damages penalty provision — apply only to qualified commercial tenants. ALL THREE of the following conditions must be met simultaneously:
All Three Conditions Must Be Met
Annual gross receipts ≤ $250 million
The tenant's total annual gross receipts from all sources must be $250 million or less. A national retailer, franchisee of a large chain, or subsidiary of a larger corporation may exceed this threshold.
Leases ≤ 10,000 SF of commercial space
The tenant's leased space must be 10,000 SF or less. A 12,000 SF tenant in a small building does not qualify regardless of revenues or building size.
Building is ≤ 100,000 SF total
The building in which the tenant leases space must be 100,000 SF or less in total. A small tenant in a large office tower or regional mall does not qualify.
| Scenario | Revenues | Tenant SF | Building SF | Qualified? |
|---|---|---|---|---|
| Small coffee shop | $1M | 1,500 SF | 40,000 SF | YES |
| Regional law firm | $80M | 8,000 SF | 75,000 SF | YES |
| National retailer | $500M | 8,000 SF | 50,000 SF | NO — revenues exceed $250M |
| Small tenant, large building | $5M | 3,000 SF | 250,000 SF | NO — building exceeds 100,000 SF |
| Mid-size tenant, small building | $50M | 15,000 SF | 60,000 SF | NO — tenant SF exceeds 10,000 |
What SB 1103 Requires Landlords to Disclose
For each qualified commercial tenant, landlords must provide an itemized CAM disclosure that includes:
- Itemized list of all CAM charges — each operating expense category with the actual amount for the reconciliation period
- Basis for each charge — the formula used, the pro-rata share percentage, the denominator (total building RSF), and the numerator (tenant RSF)
- Year-over-year comparison — any increases from the prior reconciliation period with the amount of the increase for each line item
- Contact information — a designated contact (name, phone, email) for questions about the disclosure
Timing Requirements
Initial Disclosure
Due within 90 days of lease commencement for any qualified commercial tenant. This means the first CAM disclosure must be delivered even before the first annual reconciliation period ends.
Annual Disclosure
Due within 90 days after the end of each reconciliation period. For most calendar-year reconciliations, this means the annual CAM statement must be delivered by March 31.
Penalty Structure: Treble Damages Apply Only to Qualified Tenants
SB 1103 imposes significant penalties for willful non-compliance — but the treble damages provision applies exclusively to qualified commercial tenants meeting ALL THREE conditions (revenues ≤ $250M, space ≤ 10,000 SF, building ≤ 100,000 SF). Willful violations of the disclosure obligation can result in:
- Actual damages: The financial harm the tenant suffered from the non-disclosure (e.g., costs of a self-funded audit to obtain the information)
- Treble damages: Three times actual damages — available only against willful violations affecting qualified commercial tenants as defined above
Non-willful failures (administrative oversight, missed deadlines) may not trigger treble damages, but the statute is recent and courts have not yet interpreted the willfulness standard extensively. The conservative approach is to treat all disclosure deadlines as mandatory for any tenant who might meet the qualified tenant criteria.
SB 1103 Compliance Checklist for California Landlords
Identify all tenants in buildings ≤ 100,000 SF in California
For each such tenant, confirm whether leased SF is ≤ 10,000 SF
For tenants meeting conditions 1 and 2, verify annual gross receipts are ≤ $250M (obtain tenant certification if needed)
Flag all qualified commercial tenants in lease management system
Set a 90-day clock from lease commencement for initial CAM disclosure
Set an annual 90-day deadline from reconciliation period end for each qualified tenant
Prepare itemized CAM disclosure template with pro-rata formula, prior year comparison, and contact information fields
Maintain records of each disclosure delivered (date, method, recipient) for at least the audit rights window
How SB 1103 Interacts with Existing Lease Terms
SB 1103 adds a statutory disclosure floor — it requires landlords to provide certain information regardless of what the lease says. However, SB 1103 does not override lease terms governing what expenses are recoverable, how pro-rata shares are calculated, or the total amount tenants owe.
A tenant cannot use SB 1103 to challenge the amount of CAM charges — only to obtain the disclosure they are entitled to. If the lease says management fees up to 5% are recoverable and the landlord charges 4.5%, SB 1103 does not give the tenant grounds to dispute that charge. It gives the tenant the right to receive an itemized statement showing the 4.5% management fee, its calculation basis, and any year-over-year change.
What Can Go Wrong
Applying SB 1103 obligations to all tenants without verifying qualification
Over-complying by applying SB 1103 disclosures to all tenants is administratively burdensome but not harmful. However, the reverse error — assuming that most tenants don't qualify when many do — creates real exposure. Systematically verify all three qualification criteria for every tenant in buildings at or below 100,000 SF.
Missing the 90-day disclosure window
For a calendar-year reconciliation, the 90-day window closes March 31. Landlords who send reconciliation statements in April or later — common in larger portfolios — may be violating SB 1103 for qualified tenants even if the reconciliation is otherwise accurate.
Providing a summary rather than itemized disclosure
Sending a reconciliation letter that shows "Total CAM: $45,000" without itemizing each expense category and its basis does not satisfy SB 1103. The statute requires itemization — individual line items with the formula for each. A summary total is insufficient.
Frequently Asked Questions
Does SB 1103 apply to all California commercial tenants?
No. SB 1103 applies only to qualified commercial tenants — those meeting ALL THREE conditions: (1) annual gross receipts of $250 million or less, (2) leasing 10,000 SF or less, AND (3) in a building of 100,000 SF or less. All three conditions must be satisfied simultaneously.
What must California landlords disclose under SB 1103?
An itemized list of all CAM charges, the basis (formula and pro-rata calculation) for each charge, any year-over-year increases, and a contact for questions. The disclosure must be itemized — a summary total does not comply.
What are the penalties for SB 1103 non-compliance?
Willful violations affecting qualified commercial tenants — those meeting ALL THREE conditions (revenues ≤ $250M, space ≤ 10,000 SF, building ≤ 100,000 SF) — can result in actual damages plus treble (3x) damages. The treble damages provision applies only to qualified tenants as defined.
Does SB 1103 override lease terms on what expenses are recoverable?
No. SB 1103 adds a disclosure floor but does not change what expenses are recoverable or the amount tenants owe under the lease. Tenants cannot use SB 1103 to challenge the substantive CAM charges — only to obtain the itemized disclosure.
What is the deadline for annual SB 1103 CAM disclosures?
Within 90 days after the end of each reconciliation period. For calendar-year reconciliations, this means by March 31 of the following year.
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CAM Reconciliation Software
Automate SB 1103 disclosure tracking and itemized CAM statement generation with CapVeri.
Meet the SB 1103 90-Day Deadline for Every Qualified Tenant
CapVeri generates itemized CAM disclosure statements with formula documentation and year-over-year comparisons — meeting SB 1103 requirements automatically for every qualified commercial tenant in your California portfolio.
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