What is the deadline for CAM reconciliation statements?

Most commercial leases require reconciliation statements to be delivered within 90 to 120 days after the close of the reconciliation year. For calendar year 2025, that means statements are typically due by March 31 or April 30, 2026. The exact deadline is set by each individual lease — review your lease abstract for the specific date and any consequence language for late delivery. California SB 1103 adds a statutory 90-day delivery requirement for qualifying small business tenants, regardless of what the lease says.

What if a tenant requests an audit?

Acknowledge the request in writing within 5 to 10 business days. Confirm the production deadline under the lease (typically 30 to 60 days from written notice) and identify who will coordinate document production. Most leases require you to make available: GL detail by expense category, vendor invoices and contracts, insurance certificates and premium invoices, property tax bills, management fee calculations, occupancy reports used for gross-up, and cap calculation worksheets. Landlords with organized, year-round documentation files can typically produce within 30 days. Those who reconstruct records from scratch under deadline pressure make errors that become additional audit findings.

What changed for 2026 reconciliation under BOMA 2024?

BOMA 2024 introduced updated measurement standards that affect how rentable square footage is calculated, particularly for buildings with significant amenity space, outdoor areas, and shared-use zones. For buildings that have not yet remeasured under BOMA 2024, the 2025 reconciliation may be the last year using prior-standard RSF figures. Landlords planning a remeasurement transition should notify tenants in advance, review lease language on the permitted measurement standard, and update both numerators (tenant RSF) and denominators (building total RSF) simultaneously to avoid pro-rata distortions.

How do property tax reassessments affect 2026 reconciliation?

Property tax reassessments — particularly in high-volatility markets like Harris County (Houston), Dallas, and several California counties — can create significant year-over-year swings in the tax line of the CAM pool. If a reassessment increased your 2025 tax bill substantially, confirm that the increase is fully documentable (tax bill, assessment notice, any protest filing and outcome) before including it in the reconciliation pool. Tenants will scrutinize large tax line increases. If a protest is still pending at the time of statement delivery, disclose that fact and include a true-up mechanism for when the protest resolves.

2026 CAM Reconciliation Season: Complete Prep Guide

By Angel Campa, Founder, CapVeriUpdated March 21, 2026

Quick Answer

The 2026 CAM reconciliation season covers calendar year 2025 operating expenses. Three factors make 2026 operationally significant: BOMA 2024 is now the operative measurement standard for new leases and remeasurements, California SB 1103 enters its second year of enforcement, and property tax reassessments in several major markets are creating above-average tax line volatility.

What Is Different About 2026 Reconciliation Season

Every reconciliation season has its operational rhythm. The 2026 season — covering 2025 expenses, with statements due in Q1 2026 — has three factors that make it different from prior years.

BOMA 2024 is now operative. Buildings that executed new leases or renewals in 2024 and 2025 may have RSF figures calculated under the 2024 standard. Buildings that have not yet remeasured may find themselves managing leases written under two different measurement standards simultaneously. The denominator you use for pro-rata allocation must be consistent with the measurement standard referenced in each tenant's lease — mixing standards within the same pool creates allocation errors that are difficult to explain in an audit.

SB 1103 enters year 2 of enforcement. California's small business tenant protection statute, which became effective January 1, 2025, is now in its second full reconciliation cycle. Year 2 is when enforcement patterns become visible: the California Department of Consumer Affairs has indicated that complaints from the first cycle are being evaluated. Landlords with California portfolios who handled 2025 as a transition year need to treat 2026 delivery as fully compliant — 90-day statement delivery, 30-day production response, written dispute response within 30 days of audit report.

Property tax volatility is above average. Harris County (Houston) completed a reassessment cycle in 2025 that produced significant increases for many commercial properties. Dallas, several Bay Area counties, and parts of the Atlanta metro also saw above-average reassessments. If your 2025 property tax bill increased materially, expect tenants to ask for documentation and — in some cases — for a copy of the assessment notice and any protest filed. Having that documentation ready before statements go out prevents delays.

2026 Season Timeline

Period	Tasks
October–November 2025	Pre-close expense review: identify any expenses already known to be excludable; run cap calculation preview using year-to-date actuals to estimate year-end cap impact; verify occupancy data for gross-up; confirm denominator RSF is current
December 2025	Year-end GL close: confirm all invoices through December 31 are posted; identify any late invoices expected in January and January; confirm expense coding is consistent with prior years and lease terms; pull preliminary GL detail report
January 2026	Export final GL; separate variable from fixed expenses; calculate gross-up using full-year average occupancy; apply cap restrictions by tenant; verify denominators against lease abstracts
February 2026	Calculate individual tenant allocations; prepare draft reconciliation statements; run sanity checks (sum of tenant obligations should reconcile to total pool); internal QA review
March 2026	Deliver final statements to tenants; most leases require delivery by March 31 or April 1; California SB 1103 requires delivery within 90 days of year-end (March 31 for calendar year leases)
April–June 2026	Handle tenant questions and information requests; respond to audit notices within contractual window; process true-up collections and refunds

2026-Specific Issues

BOMA 2024 Measurement Updates

BOMA 2024 introduced the most significant measurement methodology changes since BOMA 2010. Key changes affecting reconciliation:

Amenity space classification: Certain amenity spaces that were previously classified as building common area (and therefore excluded from leasable area) are now classified differently, which can affect both the building total RSF and individual tenant RSF figures.
Outdoor area treatment: BOMA 2024 provides updated guidance on how outdoor terraces, covered walkways, and exterior common areas are measured and classified. Buildings with significant outdoor amenity space may see RSF changes.
Parking structure classification: Multi-level parking structures are addressed more specifically under BOMA 2024, with implications for properties where parking-related expenses are included in the CAM pool.

For buildings that have not yet remeasured under BOMA 2024, the 2025 reconciliation uses the RSF figures from the operative lease measurement standard. Do not apply BOMA 2024 figures to a lease written under BOMA 2010 without confirming that the lease authorizes the updated standard or that the tenant has agreed in writing to the remeasurement.

SB 1103 Documentation Requirements for California Portfolios

For qualifying small business tenants (fewer than 20 employees, building with 5 or more tenants), California SB 1103 requires:

Reconciliation statement delivered within 90 days after year-end (March 31, 2026 for calendar year leases)
Statement must itemize expense categories — a single-line "CAM" figure is not sufficient
Documentation made available within 30 days of written audit request
Written response to disputed items within 30 days of the auditor's report

Landlords who delivered 2024 statements late or in insufficient detail should correct their process for 2026. The statute's enforcement window is complaint-driven, and tenant awareness of SB 1103 rights increased substantially during the 2025 cycle.

Property Tax Reassessments in Volatile Markets

Harris County (Houston) completed a major commercial reassessment cycle in 2025. Properties that saw tax increases of 15% or more should be prepared to:

Provide the full property tax bill and assessment notice to any tenant who asks
Document any protest filed and its outcome (including any reduction obtained)
Disclose any pending protest at the time of statement delivery with a stated mechanism for true-up when the protest resolves
Confirm the lease treatment of tax protest costs — some leases allow protest costs to be included in the CAM pool; others do not

Similar situations apply to Dallas County, Tarrant County (Fort Worth), and several California counties where reassessments from 2024 and 2025 are now reflected in 2025 tax bills.

15-Point Reconciliation Quality Checklist

Use this checklist before finalizing any reconciliation statement. Each item represents a documented source of error in tenant audits.

GL export reconciles to financial statements. Total expenses in the GL export match the property's audited or reviewed financial statements for the period.
All in-year invoices are included; no prior-year expenses are in the pool. Review GL dates, not invoice dates.
Excluded expenses have been removed. Capital expenditures, leasing costs, landlord-specific insurance, and other lease-excluded categories are out of the pool.
Capital expenditure amortization is handled correctly. If the lease allows amortization of certain capital items, confirm the amortization period, useful life, and annual recovery amount are per the lease terms — not an internal accounting schedule.
Variable and fixed expenses are correctly classified. The gross-up calculation depends on this split being accurate.
Gross-up occupancy figure matches the lease definition. Physical vs. economic occupancy; monthly average vs. point-in-time; the lease specifies which to use.
Gross-up target percentage is per the lease. Most leases specify 90% or 95%; do not apply a standard figure without confirming the lease.
Gross-up is applied only to variable expenses. Fixed expenses at gross-up overstates the pool.
Cap type confirmed (cumulative vs. non-cumulative) for each capped tenant. Do not assume — confirm from lease language.
Cap base year amount is the prior year's billable amount, not the prior year's actual expenses. These differ when the cap was binding in a prior year.
Cumulative cap bank balances are current and documented. Any draw from the bank is supported by a worksheet.
Denominator RSF is current and verified against lease abstracts. Includes any anchor exclusions, fixed-denominator provisions, or remeasurement updates.
Tenant RSF matches the executed lease (including any amendments). Expansion, contraction, and remeasurement amendments must be reflected.
Sum of all tenant obligations reconciles to the total pool. Run the reverse sanity check: sum up all allocated tenant shares and compare to the total includable pool after gross-up.
Statement delivery method creates a timestamped record. Certified mail, tracked courier, or confirmed electronic delivery with read receipt. The audit window starts at delivery — you need to prove the date.

Common Q1 Errors and How to Avoid Them

Error	Why It Happens	How to Avoid
Late invoices included without authorization	Vendors submit invoices in January for December services; bookkeeper posts them to the prior year	Set a hard close date; disclose late invoices separately and confirm lease authorization before including
Prior-year tax adjustments included as current-year expenses	Tax protest from 2024 resolved in 2025; refund or additional charge posted to 2025 GL	Identify the nature of any tax adjustments before including in pool; disclose separately if related to a prior year
Gross-up applied to management fees calculated as a percentage of gross revenues	Management fees sometimes look variable but are actually set by contract	Review management agreement; classify per contractual basis, not GL category
Denominator not updated after lease expiration	Tenant vacated in mid-year; denominator still reflects their RSF	Run a denominator audit every January; confirm against current rent roll
Cap worksheet uses wrong base	Bookkeeper uses actual prior-year expenses instead of prior-year billable amount	Maintain cap worksheets in reconciliation file year-over-year; prior year's billable amount should be on file
Insurance allocation across portfolio not documented	Landlord has a master policy; premium is split across properties by insurer formula	Maintain the allocation schedule from the insurer; produce it if asked; confirm the allocation method is lease-authorized

What Happens After Statement Delivery

Statement delivery starts several clocks simultaneously:

Tenant payment due date: Most leases give tenants 30 days to pay a true-up balance after statement delivery. If the tenant does not pay, the amount becomes a delinquent receivable subject to interest and late fees per the lease.
Tenant audit window: The clock on the tenant's right to request an audit starts at delivery. Track delivery dates in your system — you will need them if a tenant later claims their audit window should be extended because they did not receive the statement.
Refund obligation: If the statement shows a net credit to the tenant, most leases require the landlord to apply it against the next monthly estimate or issue a refund within 30 days. Holding refunds without authorization is a breach.
Estimate reset: Many leases require the landlord to reset monthly estimates for the upcoming year based on the reconciled actuals or an updated budget. Send updated estimate notices with or shortly after the reconciliation statement.

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