Rent Stabilization for Landlords & Property Managers

How utilities are billed to tenants depends on several factors including previous lease arrangement and how utilities are metered in a building. Utility costs paid by the landlord and not passed through to the tenant are captured in the Maintenance of Net Operating Income (MNOI) Worksheet.  

• When a meter is shared between multiple units in a building and a landlord wishes for the tenant to pay the utilities, the Landlord must follow all conditions established in Minnesota Legislative Code section 504B.215, subdivision 2a.

• If the landlord previously paid the tenant’s utilities and the landlord changes the Rental Agreement to require the tenant to pay utilities as a Pass-Through Expense, the landlord must decrease the Rent to account for the increase in the tenant’s monthly payments.  

• If a separately metered building requires tenants to pay the utility service provider directly, then payments to the utility service provider are not considered Rent.  

•  A landlord with a separately metered building who pays a utility provider directly may pass-through the costs to tenants for the utilities that are consumed by the unit.  

• If the landlord previously paid the tenant’s utilities and the landlord changes the Rental Agreement to require the tenant to pay utilities as a pass-through expense, the landlord must decrease the Rent to account for the increase in the monthly amount the tenant will pay.  

• If the landlord previously paid the tenant’s utilities and the landlord changes the Rental Agreement to require the tenant to pay the utility service provider directly or the landlord wishes to pass through the utility cost to tenants, Rent must be reduced to account for the increase in the tenant’s monthly payments.  

Review the Utilities Treatment Guide Infographic.

View the step-by-step process for requesting exception to 3% rent cap on the Rules & Processes (2025) page. You can also view an accessible PDF version of the process for requesting an exception. 

For rent increases above 3%, the following form will need to be submitted: Request for Exemption Greater than 3% - Landlord Application 

 Landlords and tenants can check out these legal, dispute resolution, and education resources.  

State and Federal Protections 

The rights and responsibilities of landlords and tenants are protected in state and federal law in addition to local ordinances. Learn more from The Office of Minnesota Attorney General's Landlords and Tenants Handbook, including the requirement that landlords provide notice of a rent increase.   

Tenant Notifications 

Tenants also have the right to be notified by City staff when their landlord submits an application requesting an exception to the 3% rent cap. City staff will also notify tenants via mail if the application is approved or denied.  

Submit a Complaint 

Tenants may also file a complaint using the Rent Stabilization Ordinance complaint form if they believe their landlord may not have complied with the Rent Stabilization Ordinance. 

Find supporting documents, forms, and worksheets on the Rules & Processes (2025) page.

The Ordinance acknowledges a landlord’s right to a Reasonable Return on Investment (“RROI”), while including a list of factors that the City must consider when determining whether to grant a landlord’s request to deviate from the limitation on rent increases.   

The City has implemented a Maintenance of Net Operating Income (MNOI) standard where a Landlord has the right to obtain a net operating income equal to the Base Year net operating income adjusted by 100% of the percentage increase in the Consumer Price Index (CPI), since the Base Year. It shall be presumed this standard provides a reasonable return. 

View the step-by-step process for requesting exception to 3% rent cap on the Rules & Processes (2025) page. You can also view an accessible PDF version of the process for requesting an exception. 

For rent increases above 3%, the following form will need to be submitted: Request for Rent Increase Greater than 3% - Landlord Application 

Other Exemption Types

Landlords of Rental units that qualify for an exception under 193A.08 are not required to obtain City approval. However, Landlords are required to provide notice to prospective tenants that the Rental unit is not subject to the ordinance.   

Low-Income Housing Provider Exception 

The ordinance aims to exempt affordable housing whose Rents are otherwise regulated by government in an agreement with a government agency. Owners who believe they are exempt from the ordinance are encouraged to reach out and confirm their exemption status with the Department.   

The Department may supply the owner with a letter indicating their status.  

New Construction Exception 

The limitation on rent increases does not apply to:

• Newly constructed residential rental properties that were issued their first building certificate of occupancy after December 31, 2004.
• Formerly non-residential properties or portions of non-residential properties, that were issued a new or renewed building certificate of occupancy because of a change in occupancy classification to residential rental property, after December 31, 2004. 

The Department keeps records of when a building was given its first certificate of occupancy from the Building Official. The owner cannot look up this information themselves.

Owners who believe they are exempt from the Rent Stabilization Ordinance because of the New Construction Exception may request the certificate of occupancy information from the Department. The Department will review the record and provide a letter including the date of occupancy.

You have the right to appeal a determination. Appeals must be in writing and delivered to the City Clerk no later than 45 calendar days from the date of the written notification. Applications for appeals may be obtained at the Office of the City Clerk, 310 City Hall, City/County Courthouse, 15 W Kellogg Blvd, Saint Paul MN  55102, Phone: 651-266-8568.

• Pursuant to Saint Paul Legislative Code section 193A.07(g), any rent increase subject to the appeal may not be imposed until there is a final determination on the appeal.
• Legislative Hearings provide the forum for reviewing appeals of City-issued determinations. The hearings are conducted by a Hearing Officer who makes a recommendation to the City Council. Individuals not satisfied with a Hearing Officer’s recommendation also have an opportunity to be heard before the City Council if they wish to appeal further.  
• For each appeal City staff will give a report and those appealing are given time to present information, photos or documents.
• Appeals by either landlords or tenants must be submitted within 45 days of the determination.  

To learn more about the City’s appeal process and find the Application for Appeal, visit  Legislative Hearings.   

No rent increase may take effect until at least 45 days from the City determination, which means staff have either approved or denied the application for exception to the 3% cap on rent increases. 

The self-certification process is intended for increase requests between 3% and 8%. 

View the step-by-step process for requesting exception to 3% rent cap on the Rules & Processes (2025) page. You can also view an accessible PDF version of the process for requesting an exception. 

The staff determination process is intended for increase requests greater than 8%.

View the step-by-step process for requesting exception to 3% rent cap on the Rules & Processes (2025) page. You can also view an accessible PDF version of the process for requesting an exception. 

For various reasons, landlords increase the services provided to tenants. Landlords who are seeking a rent increase on the basis of increased housing services but not other elements that would be considered in the Maintenance of Net Operating Income worksheet should contact the Rent Stabilization team at rent-stabilization@ci.stpaul.mn.us (email) or 651-266-8553 (phone).

Late fees are not considered rent under the Rent Stabilization Ordinance because late fees are a penalty for a late payment, rather than related to the use or occupancy of the unit. A late fee is a fairly common provision of a lease agreement and the terms of a lease may permit a landlord to recover late fees when rent was paid late. A tenant’s failure to timely pay rent as required by the terms of a lease is a breach of contract that entitles the landlord to damages and reasonable, related administrative costs.  Minnesota state law permits and regulates late fees.  A late fee should never be charged if the tenant paid rent on a timely basis.

Just Cause is in reference to rent stabilization rules and increase exceptions. This provision becomes relevant when landlords are seeking an increase exception because landlords must demonstrate that the unit has been vacated for Just Cause to be eligible to increase the rent by more than 3%. To better understand Just Cause and see a list of what constitutes Just Cause read more on the Rules & Processes (2025) page.