Commercial Tenant CAM Disclosure Requirements by State: 2026 Guide
Most U.S. states impose no specific statutory disclosure obligations on commercial landlords for CAM charges — the lease governs. But California has enacted SB 1103, and other states are seeing increased legislative attention to commercial tenant transparency. This guide covers the states with statutes and the market standards that apply everywhere else.
By Angel Campa, Founder, CapVeri · Updated April 2026
Methodology note: State law changes frequently, and this guide reflects publicly available information as of April 2026. This is not legal advice. Verify current requirements with qualified real estate counsel in the applicable jurisdiction before relying on this guide for compliance decisions.
Quick Answer
Most states have no specific commercial CAM disclosure statutes — the lease governs. California (SB 1103) is the most significant exception, imposing specific itemized disclosure requirements on qualified commercial tenants (ALL THREE of: revenues ≤ $250M, space ≤ 10,000 SF, building ≤ 100,000 SF). This guide covers the states with statutes and the market standard deadlines and audit rights windows for states that rely on lease terms.
States with Statutory CAM Disclosure Requirements
Commercial CAM disclosure statutes are rare. The commercial real estate industry has historically operated on the principle that sophisticated parties negotiate disclosure terms in the lease. That is changing at the margins, with California leading the way.
California — SB 1103 (Cal. Civil Code §827.1)
Effective: January 1, 2025
California is currently the only state with a specific, comprehensive commercial CAM disclosure statute. SB 1103 requires 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 of commercial space
- (3) In a building of 100,000 SF or less
Initial disclosure deadline
Within 90 days of lease commencement
Annual disclosure deadline
Within 90 days of reconciliation period end
Penalty for willful violation
Actual damages + treble damages (qualified tenants only)
What must be disclosed
Itemized charges, calculation basis, YOY comparison, contact info
See the full SB 1103 guide for the complete qualified tenant analysis, compliance checklist, and disclosure requirements.
Other States: Emerging Activity
Several states have seen legislative proposals or tenant advocacy efforts around commercial lease transparency:
- Oregon: Commercial lease transparency has been discussed in the context of small business tenant advocacy, but no specific CAM disclosure statute has been enacted as of April 2026.
- New York: Commercial lease disclosure proposals have been introduced in the state legislature, particularly focused on retail tenants in New York City. None have been enacted into law as of April 2026.
Monitor state legislative developments annually. The California SB 1103 model may be adopted by other states with large small-business commercial tenant populations.
Market Standard for States Without Specific Statutes
In the 49+ states without specific commercial CAM disclosure statutes, the lease governs entirely. Well-drafted leases in major commercial markets typically include the following market-standard provisions:
Reconciliation Delivery
90–120
days after lease year end
Most institutional landlords target 90 days; 120 days is the outer limit in most market leases
Audit Rights Window
12–24
months after statement delivery
12 months is institutional standard; 24 months is more common in tenant-favorable markets
Dispute Window
30–60
days after receiving statement
Failure to dispute within this window typically waives the tenant's right to challenge the statement
State-by-State Guide: 10 Major CRE Markets
| State | Specific Statute? | Reconciliation Deadline | Notes |
|---|---|---|---|
| California | Yes — SB 1103 | 90 days (qualified tenants) | Itemized disclosure required; treble damages for willful violation affecting qualified tenants (all 3 conditions: ≤$250M revenue, ≤10K SF, ≤100K SF building) |
| Texas | No | 90 days (market standard) | Lease governs; strong landlord-favorable market. Houston and Dallas/Fort Worth leases often follow BOMA standards. No statewide disclosure statute. |
| New York | No | 90–120 days (market standard) | No specific statute; NYC market has strong tenant negotiating power, resulting in bespoke disclosure provisions in larger leases. Proposals introduced but not enacted. |
| Florida | No | 90–120 days (market standard) | Lease governs. Miami, Orlando, and Tampa markets follow national institutional standards. No statewide commercial disclosure requirement. |
| Illinois | No | 90–120 days (market standard) | Chicago market has strong tenant negotiating leverage in Class A office. Custom disclosure provisions common in larger leases; smaller properties follow standard market terms. |
| Georgia | No | 90–120 days (market standard) | Atlanta market follows institutional standards. Lease governs; no statewide disclosure requirement. |
| Washington | No | 90–120 days (market standard) | Seattle market follows institutional standards. Tech-company tenants often negotiate strong audit rights. Lease governs. |
| Colorado | No | 90–120 days (market standard) | Denver market follows institutional standards. Lease governs; no statewide commercial disclosure requirement. |
| Arizona | No | 90–120 days (market standard) | Phoenix market follows institutional standards. Lease governs; no statewide commercial disclosure requirement. |
| Virginia | No | 90–120 days (market standard) | DC metro market (Northern Virginia) follows institutional standards driven by government and tech tenants. Lease governs; no statewide commercial disclosure requirement. |
Market standard deadlines are not legally required in states without specific statutes — they reflect common lease provisions in institutional-quality properties. Actual lease terms vary significantly.
Multi-State Portfolio: Compliance Framework
For landlords operating in multiple states, the practical compliance approach is to:
- 1. Identify all California properties. For each California property, identify tenants in buildings at or below 100,000 SF and evaluate whether they meet all three SB 1103 qualified tenant conditions. These tenants require statutory compliance regardless of lease terms.
- 2. Review leases for explicit disclosure provisions. In all other states, the lease governs. Review each lease for reconciliation delivery deadlines, audit rights windows, and dispute periods. Calendar these dates in your property management system.
- 3. Apply institutional market standards as a floor. Where leases are silent on disclosure details, apply the 90-day delivery / 12-month audit rights / 30-day dispute window standard as your operational baseline.
- 4. Monitor state legislative activity annually. California's SB 1103 model may be replicated in other states. States with active small-business tenant advocacy communities (New York, Oregon, Illinois) are the most likely targets for new legislation.
What Can Go Wrong
Missing SB 1103 deadlines for California qualified tenants
Landlords who apply national portfolio processes uniformly may send California CAM statements in April or May — too late for the SB 1103 90-day requirement for qualified commercial tenants. California properties with small tenants require a dedicated compliance track.
Assuming all states follow the same lease standard
Using a uniform 120-day reconciliation delivery policy may violate lease provisions in markets where the lease specifies 90 days. In states with strong tenant negotiating leverage (New York, San Francisco), lease audit rights windows may be 24 months — missing a window can waive tenant rights but also creates relationship and litigation risk for the landlord.
Treating SB 1103 treble damages as applying to all tenants
SB 1103's treble damages provision applies only to qualified commercial tenants — those meeting ALL THREE conditions (revenues ≤ $250M, space ≤ 10,000 SF, building ≤ 100,000 SF). Mischaracterizing the statute's scope either creates unnecessary alarm or understates the actual risk for the specific tenant category it covers.
Frequently Asked Questions
Do most states have specific commercial CAM disclosure statutes?
No. Most U.S. states have no specific commercial CAM disclosure statutes. The lease governs in most states. California (SB 1103) is the most significant exception as of 2026.
What are the market-standard CAM reconciliation deadlines?
Market standards in states without specific statutes: 90–120 days for reconciliation delivery, 12–24 months for tenant audit rights, and 30–60 days for tenant dispute windows after receiving the statement. These are lease standards, not legal requirements.
Does California SB 1103 apply to all California commercial tenants?
No. SB 1103 applies only to qualified commercial tenants 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.
How can a landlord protect itself in states without statutory disclosure requirements?
Use strong lease language: a defined reconciliation delivery deadline, a time-limited tenant audit rights window (12 months is standard), an estoppel provision where failure to dispute within 30–60 days waives challenge rights, and a clear definition of what supporting documentation will be provided with the reconciliation.
Related Resources
California SB 1103 CAM Guide
Full qualified tenant analysis, compliance checklist, and disclosure requirements for SB 1103.
CAM Reconciliation Deadlines
Lease-year-end deadlines and the operational calendar for on-time CAM delivery.
CAM Overbilling Landlord Liability
When CAM errors create legal liability and how to mitigate exposure.
California CAM Compliance
Complete overview of California commercial lease CAM requirements.
Manage CAM Disclosure Compliance Across Every State
CapVeri tracks reconciliation deadlines, audit rights windows, and California SB 1103 qualified tenant classifications — giving you a single compliance dashboard for your entire portfolio, regardless of how many states you operate in.
Get Started Free