Oregon Smart Lock Law 2026: Landlords Can't Make a Smartphone App the Only Way In

The law integrates door lock accessibility into Oregon's existing habitability standards under ORS 90.320, the same statute that governs other essential features a rental unit has to provide.

[Cite: ORS 90.320, as amended by Or. Laws 2025 ch. 127]

That framing matters: a habitability violation carries different legal weight than a general service complaint, putting working, accessible door access on the same statutory footing as functioning water and working smoke detectors.

The requirement applies when access control depends on phone software, operating system functionality, or active data service.

[Cite: ORS 90.320, as amended by Or. Laws 2025 ch. 127]

A landlord using a smart lock system that requires an app, a software update to function correctly, or a live data connection to unlock a door has triggered this requirement; a system that works independently of all 3 of those dependencies wouldn't need a separate alternative under this provision.

The law names several specific examples that satisfy this requirement: an access code, a key fob, a key card, or a traditional physical key.

[Cite: ORS 90.320, as amended by Or. Laws 2025 ch. 127]

A landlord has flexibility in which specific alternative to offer; what matters is that at least one of these non-phone-dependent options actually exists and works, not that every possible option is offered simultaneously.

The law responds directly to documented failure scenarios: a dead phone battery, a stalled software update, and a lost data signal, each of which can leave a tenant locked out through no fault of their own.

[Cite: Oregon Senate Majority Office, House Bill 3378 press release]

A landlord evaluating whether an access system complies with this law should specifically test it against these failure scenarios; a system that would strand a tenant during any of these common situations isn't meeting the requirement's underlying purpose, even if it technically includes some backup method.

The legislative discussion behind this bill specifically framed simpler, non-phone-dependent access methods as more reliable than app-based systems, not as an inferior fallback option.

[Cite: Oregon Senate Majority Office, House Bill 3378 press release]

A landlord shouldn't treat the non-app alternative as a rarely used backup buried in a drawer somewhere; the law's framing suggests this alternative should be a genuinely functional, readily available access method for the tenant.

The requirement doesn't depend on whether the app-based system is generally reliable or well-designed; it applies whenever access depends on phone software, operating system functionality, or data service, regardless of how infrequently that dependency actually causes a problem.

[Cite: ORS 90.320, as amended by Or. Laws 2025 ch. 127]

A landlord with a modern, well-maintained smart lock system still needs a non-app alternative in place; a low failure rate doesn't exempt a property from this habitability requirement.

Oregon's habitability statute already requires things like functioning hot and cold water and working smoke detectors; this amendment adds accessible door locks to that same list of essential features a rental unit has to provide.

[Cite: ORS 90.320, as amended by Or. Laws 2025 ch. 127]

A landlord who takes other habitability obligations seriously, promptly fixing a broken water heater or replacing a dead smoke detector battery, should apply that same seriousness to ensuring a non-app access method is actually available and working.

A tenant's access needs typically extend beyond just their own unit door to building entrances and other common access points they need to reach their home.

[Cite: ORS 90.320, as amended by Or. Laws 2025 ch. 127]

A landlord should confirm this non-app alternative requirement is met not just at the tenant's individual dwelling unit door, but at any other app-dependent access point a tenant needs to pass through to actually get home.

This law doesn't prohibit using app-based or smart lock systems; it requires a non-app alternative to exist alongside that technology.

[Cite: ORS 90.320, as amended by Or. Laws 2025 ch. 127]

A landlord can keep offering the convenience of app-based access for tenants who want it, provided the required non-app alternative, such as a physical key or access code, remains genuinely available for every tenant regardless of their phone's condition or connectivity.

Since this requirement is framed as a habitability standard, a landlord facing a tenant's claim that they were locked out should be able to show the required non-app alternative was actually available and functional at the relevant time.

[Cite: ORS 90.320, as amended by Or. Laws 2025 ch. 127]

A landlord should keep records showing when non-app access credentials, such as a physical key or an access code, were provided to each tenant, since that documentation is what would support a compliance defense if a lockout dispute arises.

The practical starting point is auditing every property using app-based or smart lock access control to confirm a genuine non-app alternative, an access code, key fob, key card, or physical key, is actually provided to each tenant, not just theoretically available.

For any property transitioning to a new access system, building in the non-app alternative from the start and documenting its distribution to tenants keeps the rollout compliant with this habitability requirement from day one.