St. Paul Rent Control Exemption Law 2025: Post-2004 Buildings

A landlord who acquired a property under that earlier structure and assumed permanent exemption was working from an incomplete picture; the exemption had a built-in expiration mechanism that the May 2025 amendment specifically removed.

6. What actually motivated this specific change

City officials and council members who supported the amendment pointed to a sharp drop in new construction as the reason for locking in the exemption. Housing starts fell roughly 80% in 2024 compared to the prior three-year average, and developers cited the rent stabilization ordinance's construction-date uncertainty as a factor discouraging new building.

[Cite: Minnesota Reformer, "St. Paul walks back rent control"]

Mayor Melvin Carter was a visible proponent of making the exemption permanent, framing the fixed date as a way to give developers and lenders more certainty when financing new residential construction in the city.

[Cite: Minnesota Reformer, "St. Paul walks back rent control"]

7. Why the vacancy increase allowance is a separate rule entirely

Some coverage of this amendment has conflated it with a change to how much a landlord can raise rent after a vacancy. That's not accurate. The just-cause vacancy allowance, letting a landlord increase rent by CPI plus 8% above the existing rent after proving the unit was vacated for just cause, lives in a different code section and wasn't touched by Ordinance 25-29.

[Cite: St. Paul Legislative Code §193A.05(b)(1)]

That vacancy allowance itself dates back to the same September 2022 overhaul that first introduced the construction-date exemption; it wasn't part of this May 2025 amendment at all.

[Cite: Minnesota Reformer, "St. Paul City Council passes sweeping overhaul of rent control ordinance"]

8. Why that distinction actually matters for compliance

A landlord managing a property that qualifies for the construction-date exemption doesn't need the vacancy allowance at all; the property is fully exempt from the 3% cap regardless of turnover. A landlord managing an older, non-exempt property still relies on the vacancy allowance exactly as it existed before May 2025, unaffected by this amendment.

[Cite: St. Paul Legislative Code §193A.05(b)(1); §193A.08(a)(3)]

Treating these as one combined change, rather than two separate and unrelated provisions, is the most common way this update gets misread.

9. How to determine whether a specific property qualifies

The relevant fact is a single date: when the property received its first building certificate of occupancy. A property issued that certificate on or after January 1, 2005 qualifies for the exemption. A property issued its certificate on or before December 31, 2004 does not, and remains under the standard 3% cap.

[Cite: St. Paul Legislative Code §193A.08(a)(3)(a)]

For a converted property, the same test applies to the date the conversion itself received its first certificate of occupancy as residential property, not the date the original structure was built for its prior, non-residential use.

[Cite: St. Paul Legislative Code §193A.08(a)(3)(b)]

10. What isn't specified about verifying that status

Neither the ordinance text nor the city's published rent stabilization guidance describes a formal process for a landlord to request or document exemption status with the city in advance.

[Cite: St. Paul Legislative Code §193A.08(a)(3)]

A landlord relying on this exemption should keep the property's certificate of occupancy on file as the underlying proof, since that's the specific document the ordinance's own language points to as the qualifying trigger.

11. How much of St. Paul's rental stock this actually affects

Despite this exemption, over 90% of St. Paul's rental housing stock remains subject to the rent stabilization ordinance's 3% cap.

[Cite: Myvillager, "Council approves amendments to St. Paul's rent control ordinance"]

That figure is a useful reality check for a landlord assuming this exemption is broadly available. It applies specifically to newer construction and qualifying conversions since 2005; it doesn't touch the large majority of the city's existing rental housing built before that date.

12. Why subsidized housing sits under a different rule entirely

Subsidized affordable housing and government-reimbursed rental units carry their own separate exemption from the rent stabilization ordinance, distinct from the construction-date exemption discussed here.

[Cite: St. Paul Legislative Code §193A.08]

A landlord operating subsidized units doesn't need to check a certificate-of-occupancy date to determine exemption status; that exemption runs on the property's subsidized or government-reimbursed status instead.

13. Why this amendment doesn't retroactively affect leases already in place

This amendment changes which properties are exempt going forward from its June 13, 2025 effective date; it doesn't reopen or invalidate a rent increase a landlord already applied, or failed to apply, under the exemption rules that existed before that date.

[Cite: St. Paul Legislative Code §193A.08(a)(3), transition clause, as amended by Ordinance 25-29]

A landlord who applied the pre-2025 rolling-window rule correctly to a rent increase before June 13, 2025 doesn't need to revisit that increase because of this change.

14. What property managers should do now

The practical starting point is pulling the certificate of occupancy date for every St. Paul property in a portfolio and sorting properties into two groups: those issued a certificate after December 31, 2004, now permanently exempt from the 3% cap, and everything else, still subject to it.

For any property near that boundary date, or any recent non-residential-to-residential conversion, confirming the exact certificate of occupancy date against the property's own records closes the most direct compliance gap this amendment creates, since a landlord operating on an assumed or approximate date risks either overcharging a non-exempt tenant or underusing an exemption the property has actually qualified for since 2005.