The Regulatory Shift: Submetering and RUBS Under Fire
Key Takeaways
- Ohio HB 173 would have put submetering companies under PUCO oversight with rate caps and mandatory registration. It passed both chambers but was vetoed in June 2026.
- Seattle's Renters' Commission has pushed to ban RUBS outright, and the Mayor identified it as a likely early target for reform.
- Virginia SB 294 was signed in April 2026. From July 1, 2027, it requires detailed records of how utility charges are calculated, available to tenants.
- Miami-Dade's model makes it explicit: using a billing vendor does not transfer compliance responsibility — the property owner stays on the hook.
- If you use RUBS without documentation, you are carrying a growing compliance liability in a rising number of jurisdictions.
For years, submetering and Ratio Utility Billing Systems (RUBS) operated in a regulatory gray zone — legal, lightly supervised, and largely left to landlords and third-party billing companies to self-police. That era is over.
This post is part of our Regulatory Shift series. For operators evaluating their billing method, see how a modern utility billing platform keeps you compliant as regulations evolve.
In 2026, legislators and regulators across the country are targeting how utilities get billed to tenants. Some want tighter oversight. Others want outright bans. Here's where things stand — and what it means for operators who depend on accurate, defensible utility billing.
This post was first published in January, while most of these bills were still moving. The status of each bill below has been updated to show where it ended up. Ohio's bill was vetoed, Minnesota's died, and Virginia's and Maryland's became law.
Ohio HB 173: Putting Submetering Companies Under PUCO
Ohio's House Bill 173 was the most significant submetering regulation bill in the country. Introduced by Rep. David Thomas with bipartisan support, the bill would have placed submetering companies under the oversight of the Public Utilities Commission of Ohio (PUCO) — a first for the state.
Key provisions included:
- Registration requirements for all submetering companies operating in Ohio
- Rate caps ensuring tenants cannot be charged above the local utility's standard service offer
- Itemized billing showing per-kWh pricing and common-area fees
- A formal complaint process giving tenants a path to challenge charges through PUCO
The bill passed the Ohio House 74-23 on March 18, 2026. The Senate passed it as a substitute and the House concurred, but it was vetoed in June 2026. Had it become law, it would have fundamentally changed how third-party billing companies operate in Ohio — requiring the same transparency and accountability that traditional utilities face.
Status (updated October 2026): Vetoed, June 2026. Not law.
Ohio operators: because HB 173 was vetoed, its registration, rate-cap, and PUCO oversight provisions don't apply. Watch for a new version in a future session.
Seattle's Campaign to Ban RUBS
Seattle hasn't passed a RUBS ban. In January 2026, the Seattle Renters' Commission formally urged the Mayor and City Council to prohibit Ratio Utility Billing Systems entirely.
The push intensified after tenants at the Qualman Apartments on 15th Ave staged a rent strike when their property manager switched from flat-rate fees to RUBS. Advocacy groups like the Puget Sound Tenants Union argue that RUBS can be used to circumvent Washington's rent stabilization limits under HB 1217, which caps most rent increases at 7% + CPI or 10%.
Mayor Wilson launched a Mayoral Renter's Survey in February 2026, with RUBS identified as "one likely early target" for reform. Current city code (SMC 7.25) requires transparency but doesn't cap RUBS charges or regulate how they interact with rent stabilization.
Status: No ordinance enacted as of October 2026.
Virginia SB 294: New Transparency Rules for Submetering
Virginia's SB 294 was signed in April 2026 and updates the Virginia Residential Landlord and Tenant Act with significant new requirements for submetering, energy allocation, and RUBS. It takes effect July 1, 2027.
The law requires landlords to:
- Provide tenants with a clear accounting of rent, fees, and utility-related charges when issuing termination notices
- Maintain detailed records explaining how utility charges are calculated
- Make those records available to tenants
The Senate passed SB 294 on a 21-19 vote on February 10, 2026, and the House passed a substitute version 75-23 on March 6. The Senate agreed to the House substitute on March 10.
Status (updated October 2026): Signed April 2026. Takes effect July 1, 2027.
Maryland Opens the Door to Water Submetering
Maryland moved in a different direction. SB 130 and HB 220, enacted as Chapters 261 and 262 of 2026, authorize individual unit water submetering — expanding on existing state law that allows submetering for gas and electricity.
The law comes with guardrails:
- Submetered water and sewer charges can't exceed what the water provider actually bills the property, and must be allocated by each unit's actual usage
- Owners can't bill units for common-area usage, non-residential usage, or leaks and poor maintenance they're responsible for
- An administrative fee of up to $1 per unit per month is allowed
Earlier versions included leak-detection and eviction provisions that were removed before the bill passed.
Status (updated October 2026): Law. Takes effect October 1, 2026.
Massachusetts Moves to Modernize Submetering Law
Massachusetts has one of the most restrictive submetering laws in the country. Current law only allows landlords to allocate heating or cooling costs to tenants if an energy monitoring system was installed before July 1, 1997 — effectively freezing submetering technology in the 1990s.
House Bill 3545 would remove that date restriction, allowing qualifying energy monitoring systems to be used regardless of installation date. The bill received a favorable report from the House Committee on Telecommunications, Utilities and Energy on March 23, 2026, and is now in the House Committee on Ways and Means.
Status (updated October 2026): In House Ways and Means. Formal sessions ended July 31, 2026, so it can only pass in informal session.
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Talk to the TeamMinnesota and Wisconsin Tried to Add Payment Protections
Two Midwestern states focused on the tenant side of utility billing:
Minnesota SF 3221 would have required landlords to give tenants at least 31 days to pay submetered or apportioned utility bills. This built on Minnesota's 2025 reforms that capped administrative fees at $8 per billing period and late fees at $5 per month. The bill died in the Senate Energy, Utilities, Environment, and Climate Committee when the Legislature adjourned in May 2026.
Wisconsin AB 1143 would have required clearer disclosure of utility charges in residential leases, including how costs are calculated for shared meters. Tenants could request detailed utility billing within 14 days, and landlords couldn't charge separate processing fees for utility payments made with rent. The bill was introduced March 13, 2026, but failed to pass before the session ended on March 23.
Status (updated October 2026): Minnesota — died in committee. Wisconsin — died at session end.
Miami-Dade's Re-metering Ordinance: A Compliance Reminder
While not new legislation, Miami-Dade County's Re-metering Ordinance deserves attention as a model for what other jurisdictions may adopt. The ordinance requires property owners — not third-party billing vendors — to register with the county, pay a $5/unit registration fee, and renew annually to lawfully resell water to tenants.
Key requirements include itemized billing (total amount, gallons consumed, computation method, meter readings), a 15-day minimum payment window, late fee caps of 10%, and under-billing adjustments limited to 6 months. Using a billing vendor does not transfer compliance responsibility — the property owner remains liable.
Status: Existing law. Ongoing compliance required.
The Bigger Picture
The legislative trend is clear: regulators want utility billing to be transparent, capped, and auditable. Ohio's PUCO oversight bill was vetoed, but the laws that did pass point the same way: Maryland's actual-cost cap for submetered water and Virginia's record-keeping mandate. Add Seattle's push to ban RUBS outright, and the direction is toward more accountability — not less.
For operators, this means three things:
- If you use RUBS, document everything. Show exactly how allocations are calculated and be prepared to defend your methodology. RUBS without documentation is a compliance liability in a growing number of jurisdictions.
- If you submeter, know your rate caps. Laws like Maryland's SB 130 set the expectation that tenants should never pay more than the utility bills. Markups are increasingly illegal.
- If you use a third-party billing vendor, you're still on the hook. Miami-Dade's model makes this explicit, and other jurisdictions are likely to follow. Compliance responsibility stays with the property owner.
The operators who invest in transparent, auditable utility billing systems now will be the ones best positioned as these regulations take effect.
Sources: Ohio Legislature (HB 173), Cincinnati CityBeat (House vote), Seattle Renters' Commission (RUBS letter), Capitol Hill Seattle Blog (rent strike, renter's survey), Virginia Legislature (SB 294), Maryland General Assembly (SB 130), Massachusetts Legislature (HB 3545), Minnesota Revisor (SF 3221), Wisconsin Legislature (AB 1143), Miami-Dade County (Re-metering info).
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Read moreWritten by
Clayton Erekson
Chief Executive Officer
Co-founder of Vitality. On a mission to redefine the future of utility management.