California · Effective January 1, 2025

California SB 1103 — the Commercial Tenant Protection Act

A guide for small commercial tenants in California on the new CAM-billing rights effective January 1, 2025, who qualifies as a Qualified Commercial Tenant (QCT), and how to activate statutory protections including treble damages for willful landlord violations.

Read your rights

Informational only · Not legal advice · Consult a California commercial real estate attorney

Six new rights for Qualified Commercial Tenants

Codified in California Civil Code §§ 827.1, 1632, 1946.1, 1946.2, 1947.12, 1950.9 — consolidated by the Commercial Tenant Protection Act (SB 1103).

Itemized backup required

Every CAM line item must include a contract, receipt, or invoice from a licensed contractor or service provider. Generic line items labeled "CAM Pool" or "Building Operating Costs" without backup do not satisfy SB 1103.

18-month look-back limit

Landlord can only bill costs incurred within the prior 18 months OR reasonably expected within the next 12 months. Stale costs from years ago can no longer appear on your reconciliation.

Signed landlord attestation

Each annual reconciliation must be accompanied by the landlord's signed, dated written attestation that the amounts charged are true and correct. Putting the landlord on record creates personal accountability.

No double-recovery

Costs reimbursed by insurance or paid directly by the tenant to a third party cannot be passed through in CAM. Double-billing — historically common in CAM disputes — is now statutorily prohibited for QCTs.

Treble damages on willful violations

A landlord who willfully violates the SB 1103 standard is liable for three times the actual overcharge, plus the tenant's reasonable attorney's fees and costs even without a prevailing-party clause in the lease.

Translation requirements

If the lease was negotiated in Spanish, Chinese, Tagalog, Vietnamese, or Korean, the landlord must provide notices in that language. Catches landlords who negotiate verbally in a non-English language then deliver English-only legal notices.

How to activate your SB 1103 rights

Three steps. The first one is the gate — without it, none of the protections apply.

  1. 1

    Confirm you qualify as a QCT

    You must be one of: a microenterprise (≤5 employees including the owner, per Cal. Govt. Code §12100.83); a restaurant with under 10 employees; or a nonprofit with under 20 employees. Most single-location small operators in California qualify under one of these.

  2. 2

    Send the written self-attestation notice

    Use a written, signed notice that states you qualify as a QCT and identifies which category applies. This must be sent in the 12 months before you assert your rights. We've drafted a copy-paste-ready template you can adapt and send today — takes about 10 minutes.

  3. 3

    Check next year's reconciliation against the standard

    When your next annual CAM reconciliation arrives, verify it meets the SB 1103 standard: itemized backup, 18-month look-back, signed landlord attestation, no double-recovery. ReCAM's free CAM Cross-Check scores it in 30 seconds; the $99 Pro Reconciliation produces a detailed PDF report.

Why most California tenants haven’t activated

SB 1103 took effect in January 2025. Most landlords have not proactively notified their small-business tenants of their new rights — there's no legal requirement to do so. And the law requires the tenant to take the first step (sending the self-attestation notice).

The result: a time-limited window in which a small tenant who acts early can lock in statutory protections before their landlord adjusts its CAM accounting in response. Once a wave of QCT notices lands, expect sophisticated landlords to push back via lease renegotiation or higher base rent. Early movers benefit most.

How ReCAM helps

Three tools that pair with SB 1103 — two free, one paid. Pick whichever matches where you are.

Free QCT Template

A copy-paste-ready self-attestation notice. Identifies which QCT category you qualify under and triggers your landlord's SB 1103 obligations.

Free CAM Cross-Check

Type three numbers from your lease and most recent reconciliation. 30-second math check that flags pro-rata-share inflation, load-factor drift, and market outliers.

Pro Reconciliation — $99

Upload your full annual reconciliation. Detailed PDF report citing each finding to its source — SB 1103 compliance, line-item analysis, YoY drift, market comparison. Useful for your attorney or as a demand-letter exhibit.

Frequently asked questions

What is California SB 1103?
California Senate Bill 1103, known as the Commercial Tenant Protection Act, is a state law that took effect January 1, 2025. It gives small commercial tenants — called 'Qualified Commercial Tenants' or QCTs — new statutory rights on how their landlord bills them for operating costs (CAM), rent increases, and lease termination. The bill was signed by Governor Gavin Newsom on September 30, 2024.
Who qualifies as a Qualified Commercial Tenant (QCT) under SB 1103?
Three categories of small commercial tenants qualify: (1) a microenterprise — defined under California Government Code §12100.83 as a business with 5 or fewer employees including the owner; (2) a restaurant with fewer than 10 employees; or (3) a nonprofit organization with fewer than 20 employees. The tenant must also send the landlord a written self-attestation notice within the prior 12 months to activate QCT protections.
What rights does SB 1103 give Qualified Commercial Tenants?
QCTs are entitled to: an 18-month look-back limit on operating cost charges; itemized supporting documentation (contracts, receipts, or invoices from licensed contractors) for every CAM line item; a signed and dated landlord attestation that the amounts are true and correct; prohibition on double-recovery from insurance proceeds; and translation requirements when the lease was negotiated in Spanish, Chinese, Tagalog, Vietnamese, or Korean.
What are the penalties for SB 1103 violations?
A landlord who willfully violates SB 1103 faces treble damages — three times the actual overcharge amount. Tenants are also entitled to reasonable attorney's fees and costs even without a prevailing-party clause in the lease, injunctive relief, and punitive damages for oppression, fraud, or malice. A $5,000 CAM overcharge can become a $15,000+ recovery with fees in court.
How do I activate my SB 1103 rights as a small business tenant?
You must send your landlord a written self-attestation notice stating you qualify as a QCT and identifying which category (microenterprise, restaurant, or nonprofit) applies. The notice must be sent within the 12 months before you assert your SB 1103 rights. Most small tenants have not yet sent this notice. ReCAM provides a free template you can copy, fill in, and send today.
Does SB 1103 apply to my existing lease?
SB 1103 applies to commercial leases executed or renewed on or after January 1, 2025; to month-to-month tenancies regardless of original lease date; and to pre-2025 leases that do not contain CAM/operating-cost provisions. If your lease pre-dates 2025 and contains CAM provisions, the rent and notice protections may still apply but the CAM-specific provisions may not — consult a California commercial real estate attorney for guidance specific to your lease.
What is a Qualified Commercial Tenant self-attestation notice?
A written, signed notice from the tenant to the landlord stating that the tenant qualifies as a Qualified Commercial Tenant under SB 1103 and identifying which category — microenterprise (≤5 employees), restaurant (<10 employees), or nonprofit (<20 employees) — applies. Sending this notice activates the tenant's statutory rights to itemized CAM backup, the 18-month look-back, the signed landlord attestation, and the treble-damages remedy for willful violations.
Is my landlord required to give me an itemized CAM bill under SB 1103?
Yes — if you are a QCT and have sent the self-attestation notice, your landlord must provide itemized supporting documentation for every CAM line item. This means a contract, receipt, or invoice from a licensed contractor or service provider for each charge. Generic line items labeled 'Building Operating Costs' or 'CAM Pool' without underlying documentation do not satisfy SB 1103's itemization requirement.
How does ReCAM help with SB 1103?
ReCAM provides two free tools and one paid tool: (1) a free QCT self-attestation template you can send to your landlord today; (2) a free CAM Cross-Check that scores your annual reconciliation against the SB 1103 standard (itemization completeness, look-back compliance, pro-rata share math, double-recovery flags); and (3) a $99 Pro Reconciliation analysis with a detailed PDF report citing each finding to its source — useful for tenant attorneys, CAM auditors, or your own demand letter.

Informational only · Not legal advice. This page explains the public-domain text of California SB 1103 and how ReCAM's tools can help you comply with and benefit from it. It is not legal advice and does not create an attorney-client relationship. Consult a California commercial real estate attorney for guidance specific to your lease and situation.