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

Before May 2025, a St. Paul property's construction-date exemption from the rent cap wasn't fixed. It ran on a rolling 20-year window, so a building built or converted in, say, 2005 would have eventually aged out of that exemption and fallen back under the 3% cap once it turned 20 years old. The May 2025 amendment replaced that countdown with a hard date.

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

A property that qualifies under the December 31, 2004 cutoff now stays exempt indefinitely. There's no future date on which it reverts to being capped.

The operative language states that the limitation on rent increases doesn't apply to newly constructed residential rental properties issued their first building certificate of occupancy after December 31, 2004, and separately extends the same treatment to properties that changed occupancy classification from non-residential to residential and were issued their first certificate of occupancy after that same date.

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

Those two categories, new construction and qualifying conversions, are treated identically under the amended language. A converted warehouse and a ground-up new apartment building qualify the same way, based purely on when each received its first certificate of occupancy.

The City Council adopted this amendment on May 7, 2025, by a 4-3 vote. Council Members Anika Bowie, Saura Jost, Rebecca Noecker, and Matt Privratsky voted in favor; Council Members Cheniqua Johnson, Hwa Jeong Kim, and Nelsie Yang voted against.

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

The Mayor's Office signed the ordinance May 14, 2025, and it took effect 30 days after passage, approval, and publication, landing on June 13, 2025.

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

The exemption itself isn't new. It traces back to the City Council's September 21, 2022 overhaul of the rent stabilization ordinance, which took effect January 1, 2023 and first introduced a construction-date exemption, at that point built as a rolling 20-year window rather than a fixed date.

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

That 2022 amendment also removed the original ordinance's blanket restriction on rent increases after tenant turnover, replacing it with the vacancy allowance discussed below. Before that change, St. Paul's original 2021 ballot-measure ordinance was widely described as one of the strictest rent control policies in the country, with no significant exemptions built in at all.

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

Under the 2022-era rolling structure, a property's exemption status wasn't a one-time determination. A building exempt today because it was under 20 years old would, absent further council action, have eventually crossed that threshold and become subject to the 3% cap on its own, purely by aging.

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

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.

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"]

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"]

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.

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)]

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.

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.

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.

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.

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.