In-House Utility Billing Software | Vitality

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.

Ohio HB 173: Putting Submetering Companies Under PUCO

Ohio's House Bill 173 is the most significant submetering regulation bill in the country right now. Introduced by Rep. David Thomas with bipartisan support, the bill would place submetering companies under the oversight of the Public Utilities Commission of Ohio (PUCO) — a first for the state.

Key provisions include:

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, and has been referred to the Senate Public Utilities Committee. If enacted, it would fundamentally change how third-party billing companies operate in Ohio — requiring the same transparency and accountability that traditional utilities face.

Status: Passed House. Pending in Senate Public Utilities Committee.

Ohio operators using third-party billing services should watch this bill closely. If HB 173 passes the Senate, billing vendors will face registration, rate caps, and PUCO oversight — which could affect pricing, billing formats, and dispute resolution processes.

Seattle's Campaign to Ban RUBS

Seattle hasn't passed a RUBS ban yet — but the momentum is building fast. 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. Active advocacy campaign with mayoral support.

Virginia SB 294: New Transparency Rules for Submetering

Virginia's SB 294 has passed both chambers of the General Assembly and updates the Virginia Residential Landlord and Tenant Act with significant new requirements for submetering, energy allocation, and RUBS.

The bill 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 upon request at no cost

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: Passed both chambers. Awaiting governor's signature.

Maryland Opens the Door to Water Submetering

Maryland is moving in a different direction. SB 130 and HB 220 would authorize individual unit water submetering — expanding on existing state law that allows submetering for gas and electricity.

But the bills come with guardrails:

Landlords cannot charge tenants more than the actual water and sewer costs billed by the utility
Submeters must include leak detection monitors
Unpaid water charges cannot be treated as unpaid rent in eviction proceedings
New record-keeping and billing transparency requirements apply

SB 130 has a hearing scheduled for April 2, 2026. HB 220 had its hearing on February 3.

Status: Active. Moving through the General Assembly.

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: Active. In House Ways and Means Committee.

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Minnesota and Wisconsin Add Payment Protections

Two Midwestern states are focused on the tenant side of utility billing:

Minnesota SF 3221 would require landlords to give tenants at least 31 days to pay submetered or apportioned utility bills. This builds on Minnesota's 2025 reforms that capped administrative fees at $8 per billing period and late fees at $5 per month. The bill is pending in the Senate Energy, Utilities, Environment, and Climate Committee.

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: Minnesota — active, 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. Whether it's Ohio requiring PUCO oversight of submetering companies, Seattle pushing to ban RUBS outright, or Virginia mandating detailed record-keeping, 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. Bills like Ohio's HB 173 are setting the expectation that tenants should never pay above the local utility rate. 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 Legislature (SB 130), Massachusetts Legislature (HB 3545), Minnesota Revisor (SF 3221), Wisconsin Legislature (AB 1143), Miami-Dade County (Re-metering info).

Jan 28, 2026

The Regulatory Shift: Submetering and RUBS Under Fire

Key Takeaways