What Property Owners & Managers  Should Know About AB2801 (Doing Business in California )


California apartment communities are racing to adapt to Assembly Bill No. 2801, a newly implemented regulation that dramatically increases documentation requirements surrounding tenant move-ins and move-outs. Approved by the governor on September 19, 2024, AB-2801 is being phased in throughout 2025 and places strict new conditions on how landlords manage, document, and justify security deposit deductions.

What AB-2801 Changes

At the heart of AB-2801 is enhanced tenant protection and accountability in the handling of security deposits. The law establishes a step-by-step framework that property managers must follow when assessing damages and issuing itemized deductions. Failure to follow the new procedures in good faith may forfeit a landlord’s right to make any deductions at all.

One of the most labor-intensive updates is the requirement for time-stamped photo documentation. Beginning April 1, 2025, landlords must take photographs of the unit after a resident moves out but before any cleaning or repairs begin. These images must be shared with the resident along with an itemized statement detailing any security deposit charges. This package must be delivered within 21 days of the resident’s move-out date and may not be sent earlier than:

  • The date notice is provided to terminate the tenancy; or

  • 60 calendar days prior to the end of a fixed-term lease.

Landlords must also take follow-up photos after the completion of repairs or cleaning. For tenancies starting on or after July 1, 2025, landlords are additionally required to take photos at the beginning of the lease to document the condition of the unit at move-in.

Clarified Security Deposit Rules

In addition to procedural updates, AB-2801 reinforces existing rules and introduces key changes:

  • As of July 1, 2024, most security deposits are capped at one month’s rent, though smaller landlords may be exempt.

  • Permissible deductions include:

    • Unpaid rent

    • Repair of damages beyond normal wear and tear

    • Cleaning costs necessary to restore the unit to its original level of cleanliness (as applicable under tenancy start date)

    • Future default on lease obligations involving property restoration (if authorized in the rental agreement)

Crucially, all deductions must be reasonable and backed by evidence such as receipts, repair invoices, and the newly required photo documentation.

What Can No Longer Be Charged

One of the most notable changes is the treatment of general cleaning expenses. For example, landlords can no longer automatically deduct the cost of routine carpet cleaning from a tenant’s deposit unless there’s legal cause. Carpet cleaning must be justified by damage beyond normal wear or an evident need to return the carpet to its original move-in condition. Making unwarranted deductions—particularly without proof—may be considered a violation.

Compliance Challenges for Property Managers

As communities prepare for the law’s full rollout, many operators are feeling the time crunch. The complexity of new documentation requirements has forced some teams to rely on time-consuming manual processes—uploading inspection photos, organizing them into folders, and creating itemized statements from scratch.

While the legislation aims to improve transparency, reduce tenant-landlord disputes, and curb abusive practices, it has also introduced operational challenges for multifamily housing teams already managing high volumes of turnover. Property managers across the state are now reevaluating their workflows, exploring software tools, and training staff to ensure they don’t miss a step—because failing to meet the new standards could result in the forfeiture of their right to retain any part of a security deposit.


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