§ COMPLIANCE REFERENCE

    California Rental Compliance Guide.

    Everything you need to know about AB 2801 (photo documentation), AB 414 (electronic deposit returns), and AB 628 (appliance requirements).

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    IN EFFECT · AB 2801
    Photo Documentation

    Photo documentation requirements for security deposit deductions. Now required for all move-out inspections. No photos = no deductions.

    IN EFFECT · AB 414
    Electronic Returns

    If rent or the deposit was collected electronically, the refund must also be returned electronically unless both parties agree in writing to another method.

    IN EFFECT · AB 628
    Appliances

    Working stoves and refrigerators required for any lease entered, amended, renewed, or extended on or after January 1, 2026.

    PENALTIES · NON-COMPLIANCE
    Up to 2x deposit in bad faith penalties
    No photos = cannot claim deductions
    Miss 21 days in bad faith = up to 2× deposit in statutory damages
    § 1 · AB 2801

    AB 2801 Overview

    AB 2801 amended California Civil Code §1950.5, now requiring landlords to provide timestamped photographic evidence when claiming security deposit deductions for damages beyond normal wear and tear. This law is now in effect — move-out photos since April 1, 2025, and move-in photos since July 1, 2025. For the full landlord playbook, see our guide on AB 2801 photo documentation.

    Move-In Documentation Required
    Photos must document the condition at move-in to establish baseline
    Move-Out Documentation Required
    Photos must document condition at move-out to support any deduction claims
    Comparison Required
    Landlords must provide before/after photo comparisons for each claimed damage
    § 2 · STANDARDS

    Photo Documentation Standards

    All inspection photos must meet specific requirements to be considered valid evidence for security deposit deductions.

    REQUIREDTimestamp

    All photos must include a verifiable timestamp showing when the photo was taken. BiPact automatically captures and preserves photo timestamps.

    REQUIREDRoom/Area Label

    Each photo should be labeled with the room or area it documents (e.g., Kitchen, Master Bedroom, Bathroom).

    RECOMMENDEDDetailed Caption

    Add descriptions for any damage or notable conditions to make comparison easier.

    RECOMMENDEDMultiple Angles

    Take photos from multiple angles for each area, especially where damage exists.

    § 3 · DEADLINE

    21-Day Deadline Rules

    CRITICAL TIMELINE

    You have exactly 21 calendar days (Civil Code §1950.5(h)(1)) from when the tenant vacates to return the security deposit or provide an itemized statement of deductions with supporting documentation. Missing this deadline is the most common trigger for the bad faith penalty — see what landlords actually pay when they miss it.

    01
    Complete Move-Out Inspection
    Inspect the unit within a reasonable time after possession is returned — before any cleaning or repair work begins — so AB 2801 move-out photos document the condition the tenant left. (The §1950.5(f) pre-move-out walkthrough — which happens no earlier than 2 weeks before the end of tenancy — is a separate, earlier step covered in §9 below.)
    02
    Document All Damages
    Take timestamped photos comparing move-in vs. move-out condition
    03
    Obtain Repair Estimates/Receipts
    Get documentation for all repair costs (required for deductions over $125)
    04
    Send Itemized Statement
    Mail statement with photos and receipts to tenant's forwarding address
    § 4 · RECEIPTS

    Receipt Requirements

    $125 THRESHOLD

    For any single deduction exceeding $125 (Civil Code §1950.5(h)(4)), you must provide documentation such as receipts, invoices, or written estimates from licensed contractors. For the full landlord template, see our guide on itemized deduction statements.

    Repairs Already Completed
    Provide actual receipts or invoices showing the work performed and amount paid
    Repairs Not Yet Completed
    Provide written estimates from licensed contractors. You may withhold estimated amounts and must provide receipts within 14 days of completion.
    § 5 · AB 414

    AB 414: Electronic Deposit Returns

    Assembly Bill 414 (effective January 1, 2026) amended California Civil Code Section 1950.5. The trigger is how rent or the deposit was originally collected: if you accepted those payments electronically, you must return the deposit electronically too — unless you and the tenant agree in writing to another method.

    WHAT THIS MEANS FOR LANDLORDS

    Return the deposit using an electronic method available to you (typically the same channel you used to collect rent — ACH, payment app, etc.). You are not required to sign up for a specific service a tenant names; you are required to offer an electronic path when rent came in electronically. Any departure from that (a mailed check, for example) requires a written agreement between you and the tenant.

    Trigger: Electronic Rent Collection
    If you collected rent or the deposit electronically during the tenancy, the refund must also be electronic by default. If you only ever accepted paper checks, AB 414 does not apply.
    Written Notice of Tenant Right
    Landlords must notify the tenant in writing of the right to receive an electronic refund. Document this notice so you can prove it was provided.
    Opt-out Requires Written Agreement
    If both parties want to use another method (mailed check, cashier's check, etc.), that agreement must be in writing. A tenant cannot unilaterally demand a different method, and a landlord cannot unilaterally mail a check if rent was paid electronically.
    Documentation Required
    Keep records of how the deposit was returned including the method, amount, date, and any confirmation or transaction numbers.
    CHECK STILL ALLOWED

    A mailed check is still valid when rent was never collected electronically, or when both parties agree in writing to use a check. If rent came in electronically, the electronic refund is the default unless the written-agreement opt-out is on file.

    BIPACT COMPLIANCE FEATURE

    BiPact allows tenants to specify their preferred refund method on their dashboard. When generating the final deposit statement, landlords can see the tenant's preference and record how the deposit was returned with proof documentation.

    § 6 · CATEGORIES

    Deduction Categories

    ALLOWABLE DEDUCTIONS
    • Unpaid rent or utilities owed
    • Damage beyond normal wear and tear
    • Cleaning costs if unit not left reasonably clean
    • Restoring alterations (if not permitted in lease)
    • Key/remote replacement if not returned
    NOT DEDUCTIBLE (NORMAL WEAR)
    • Faded paint or small nail holes
    • Worn carpet in traffic areas
    • Loose door handles or hinges
    • Minor scuffs on walls or floors
    • Worn bathroom caulking
    § 7 · AB 628

    AB 628: Appliance Requirements

    Assembly Bill 628 (effective January 1, 2026) added paragraphs (10) and (11) to California Civil Code Section 1941.1, making a working stove and refrigerator part of the implied warranty of habitability. The requirement applies to any lease entered into, amended, renewed, or extended on or after January 1, 2026 — not retroactively to existing tenancies.

    WHAT THIS MEANS FOR LANDLORDS

    For any new lease signed on or after January 1, 2026 — or any existing lease that gets amended or renewed after that date — the unit must be delivered with a working stove/range and refrigerator. A recalled appliance must be repaired or replaced within 30 days of notice.

    Stove/Range Requirement
    Every rental unit must have a working stove or range. This includes all burners functioning and the oven operating at proper temperature.
    Refrigerator Requirement
    Every rental unit must have a working refrigerator that maintains proper cooling temperature. The freezer compartment must also function correctly.
    30-Day Recall Rule
    If a supplied stove or refrigerator is subject to a manufacturer or public-entity recall, the landlord must repair or replace it within 30 days of receiving notice of the recall.
    TENANT-PROVIDED EXCEPTION

    The tenant may elect to supply their own refrigerator — but this election must be made at lease signing and documented in the lease itself. The exception applies only to the refrigerator; the stove/range is still the landlord's responsibility. Existing tenancies are unaffected until the lease is amended or renewed on or after January 1, 2026.

    BIPACT COMPLIANCE FEATURE

    During move-in inspections, BiPact prompts you to verify appliance presence and working condition in the kitchen. This creates a documented record of AB 628 compliance at the start of each tenancy.

    § 8 · STATUTE

    Statute of Limitations

    Understanding the legal timeframes for security deposit disputes is crucial for both landlords and tenants. California law provides specific windows during which legal action can be taken.

    KEY TIMEFRAMES · SECURITY DEPOSIT CLAIMS

    Tenants typically have between 3 and 4 years from the date of move-out to file a lawsuit for wrongful withholding of a security deposit. The statutory §1950.5 claim is generally subject to a 3-year limitation period under California Code of Civil Procedure §338(a) (liability created by statute); a claim pleaded as breach of a written lease may have a 4-year limitation period under CCP §337. Practitioners often plead both.

    Statutory §1950.5 Claim — 3 Years

    California Code of Civil Procedure §338(a) provides a 3-year statute of limitations for liability created by statute, which covers the wrongful-withholding remedy under Civil Code §1950.5. The clock starts when the landlord was required to return the deposit (21 days after move-out).

    Written Contract Claim — 4 Years

    If the case is pleaded as a breach of the written lease itself, the 4-year statute under CCP §337 may apply. Most practitioners plead both the statutory and contract theories so the longer window is preserved.

    Oral Agreement Claims — 2 Years

    For rental agreements made verbally without a written lease, the statute of limitations is 2 years under California Code of Civil Procedure Section 339.

    Small Claims Court

    Security deposit disputes up to $12,500 can be filed in Small Claims Court. The same statute of limitations applies (4 years for written leases, 2 years for oral).

    Bad Faith Penalty

    Under California Civil Code §1950.5(m), if a landlord retains any part of the deposit in bad faith, a court may award statutory damages of up to twice the amount of the security, in addition to actual damages. California practitioners most commonly apply the 2× figure to the portion wrongfully withheld; the statute text refers to "the security" (the full deposit), and courts have discretion on the calculation. This penalty is subject to the same limitation periods.

    BIPACT'S 7-YEAR AUTOMATIC RETENTION

    BiPact automatically retains all your documentation (photos, receipts, statements, communications) for 7 years after a tenant moves out—covering the full statute of limitations plus a safety buffer. You'll receive reminders before any data is archived or deleted. See our Data Retention Policy.

    § 9 · CIVIL CODE 1950.5(f)

    Pre-Move-Out Walkthrough

    California Civil Code Section 1950.5(f) requires landlords to notify tenants in writing of their right to request an initial inspection before move-out. This walkthrough protects both parties by identifying potential deposit deductions in advance and giving tenants time to make repairs. Full landlord playbook: how to run a §1950.5(f) walkthrough.

    Written Notice

    Must inform tenant in writing of their right to request a pre-move-out inspection. The notice must be provided before the tenancy ends.

    Scheduling Window

    The inspection must be scheduled no earlier than 2 weeks before the lease end date.

    48-Hour Notice

    Must give at least 48 hours written notice of the inspection date and time.

    Itemized List

    Must provide a written, itemized list of all deficiencies found during the inspection.

    Fix Opportunity

    Tenant has until move-out to remedy the listed deficiencies and avoid deposit deductions.

    One Bite Rule (with Exceptions)

    Landlord cannot deduct for visible damage omitted from the walkthrough deficiency list — unless the damage occurred after the inspection, was hidden by the tenant's possessions during the inspection, or was not reasonably identifiable at the time (§1950.5(f)).

    BIPACT AUTOMATES COMPLIANCE

    BiPact's walkthrough feature handles formal written notice delivery, tenant response tracking, scheduling with date validation, room-by-room documentation, and deficiency list generation — ensuring full compliance with 1950.5(f).

    § 10 · CHECKLIST

    Compliance Checklist

    Move-In Inspection
    Schedule inspection with tenant present (recommended)
    Take timestamped photos of all rooms and areas
    Document any existing damage or conditions
    Label each photo with room/area name
    Verify stove and refrigerator are present and working (AB 628)
    Have tenant sign inspection report (recommended)
    Store photos securely with timestamps preserved
    Pre-Move-Out Walkthrough
    Send written notice to tenant of right to request walkthrough
    Document tenant's response (requested or declined)
    Schedule walkthrough within legal window (no earlier than 2 weeks before lease end)
    Provide 48-hour written notice of walkthrough date/time
    Conduct walkthrough with tenant present
    Document all deficiencies with photos
    Provide itemized deficiency list to tenant
    Allow tenant fix period before move-out
    Move-Out Inspection
    Complete inspection within 21 days of tenant vacating
    Take timestamped photos matching move-in locations
    Document all damages and compare to move-in condition
    Note cleaning issues if unit not left clean
    Capture multiple angles for significant damages
    Have tenant sign if present
    Deduction Statement
    Calculate 21-day deadline from move-out date
    Itemize each deduction with description and amount
    Attach move-in/move-out photo comparisons
    Include receipts for deductions over $125
    Calculate refund amount (deposit minus deductions)
    Send statement to tenant's forwarding address
    Keep copies of all documentation for 4+ years
    Deposit Return (AB 414)
    Check tenant's preferred refund method
    Use electronic payment if tenant requested
    Record the payment method and amount
    Save confirmation/transaction number
    Upload proof of payment (screenshot/receipt)
    Notify tenant that refund has been sent
    § 11 · DOCUMENTS

    Documents & Downloads

    BiPact generates several types of documents to ensure you have complete legal protection. Understanding what each document contains helps you use them effectively.

    Itemized Security Deposit Statement
    REQUIRED BY LAW

    The itemized deposit statement meeting AB 2801 requirements that you must provide to tenants within 21 days of move-out.

    Property and tenant details
    Itemized deductions with amounts
    Linked damage photos
    Attached receipts (for $125+)
    Refund calculation
    21-day deadline notice
    Legal Evidence Bundle (PDF)
    COURT-READY

    Comprehensive PDF compilation designed for legal proceedings. Use this if a tenant disputes deductions or takes you to small claims court.

    Side-by-side photo comparisons
    Digital signatures with metadata
    Full message history
    Dispute records & responses
    Appliance compliance (AB 628)
    SHA256 hash for authenticity
    Evidence Photo Archive (ZIP)
    BACKUP & ARCHIVAL

    Complete archive of all inspection photos with embedded metadata for tamper detection. Keep this for your records throughout the 7-year retention period.

    All move-in & move-out photos
    Organized by room/area
    EXIF metadata preserved
    BiPact watermark embedded
    Tenant Portal
    FREE FOR TENANTS

    Tenants get their own free portal to participate in inspections, view statements, dispute deductions, and track their deposit refund throughout the process.

    Participate in inspections
    Upload their own photos
    Dispute deductions
    Track refund status
    WHY MULTIPLE DOCUMENTS?

    The Itemized Statement is what you legally must provide to tenants. The Evidence Bundle and Photo Archive are for your protection—they provide the comprehensive documentation you'd need if a tenant disputes your deductions or takes legal action. BiPact stores everything for 7 years, covering the full statute of limitations.

    § RELATED READING
    NEED LEGAL ADVICE?

    This guide provides general information about AB 2801, AB 414, and AB 628 requirements. For specific legal questions about your situation, consult with a licensed California real estate attorney or your local legal aid office. Statutory text is available at leginfo.legislature.ca.gov.