DC Move-Out Debt Collections Law 2026: 45-Day Window

Put together, these three pieces sequence into a clear process: notify within 45 days of move-out, give the tenant 30 days to dispute, and hold the account for at least 60 days from service before it can be escalated to collections. A housing provider moving straight from move-out to a collections referral, without documented notice and time for a dispute, is now out of compliance with the statute regardless of whether the underlying debt claim itself is valid.

5. The ban on habitability-service fees

Separately from the collections notice rules, the same act bars a housing provider from charging a fee for services required to maintain a unit in a condition consistent with the implied warranty of habitability. That specifically includes utilities, trash removal, locks, and administrative billing fees tied to those services.

[Cite: D.C. Official Code § 42-3505.10(b-2), as added by D.C. Law 26-156]

The underlying logic is direct: if a service is something the landlord is already legally obligated to provide as part of keeping the unit habitable, charging a separate fee for it isn't permitted, whether that fee is framed as a utility surcharge, a trash fee, or an administrative charge for processing either one.

6. The common-area utility ban, on its own separate timeline

This is the detail worth flagging precisely, since it's easy to assume the whole act moved on one date. A new section, 42-3505.11, specifically bars a housing provider from separately charging tenants for utility costs accrued by the building's common spaces or by vacant units. That provision doesn't take effect until January 1, 2027, later than the August 14, 2026 effective date that applies to the rest of the act, including the move-out notice and habitability-fee provisions described above.

[Cite: D.C. Official Code § 42-3505.11]

A property manager who's already compliant with the notice and habitability-fee rules shouldn't assume the common-area utility rule is live yet; it has its own separate runway before enforcement begins.

7. Ratio Utility Billing isn't banned outright

The common-area utility provision doesn't eliminate ratio utility billing for master-metered buildings. The statute specifically preserves a housing provider's ability to use a Ratio Utility Billing System to allocate master-metered utility charges to tenants, subject to the section's other limitations, using formulas based on square footage, occupancy, or number of bedrooms.

[Cite: D.C. Official Code § 42-3505.11]

What's prohibited is folding common-area and vacant-unit consumption into what gets billed to occupied units. A RUBS formula that allocates based on one of the three permitted methods, without padding the total with common-area or vacant-unit usage, remains a lawful way to handle master-metered utility costs once the January 2027 provision takes effect.

8. Why DC structured this as two separate effective dates

Splitting the common-area utility ban onto its own later timeline, rather than bundling it with the rest of the act, gives housing providers a longer runway specifically for a provision that likely requires changes to metering, allocation methodology, or billing software, compared to the notice and fee-ban provisions, which mostly require procedural and documentation changes that can be implemented faster.

[Cite: D.C. Law 26-156, effective date provisions]

9. No funding contingency attached

Some DC Council legislation includes a clause making certain provisions contingent on funding being included in an approved budget. This act doesn't contain that kind of language. Its effective-date provision follows the standard path, Mayoral approval followed by the usual congressional review period under the Home Rule Act, and nothing in the text ties any of these three provisions to a future appropriation.

[Cite: D.C. Law 26-156, effective date section]

That's a useful confirmation for compliance planning specifically: there's no funding-dependent uncertainty hanging over whether or when these rules actually take hold, beyond the two effective dates already described.

10. What property managers should do now

The practical starting point is building the 45-day notice into the standard move-out workflow, with photographic or documentary support attached from the start rather than produced only if a dispute arises. A checklist that flags the 45-day, 30-day, and 60-day milestones for every move-out with an alleged balance keeps a provider from accidentally referring an account to collections before the required hold period has actually run.

For utility billing specifically, a property manager relying on a ratio utility billing system for master-metered buildings should confirm the allocation formula is genuinely based on square footage, occupancy, or bedroom count, and doesn't fold in common-area or vacant-unit consumption, well before the January 2027 deadline for that specific provision arrives.