AB 2801, explained: what California landlords have to photograph now

If you keep any part of a tenant's security deposit for cleaning or repairs in California, you now have to show your work in photographs. That is the short version of AB 2801, which the Legislature passed in 2024 and which amended Civil Code § 1950.5 — the section that has governed security deposits in this state for decades.

The change matters most to small landlords, because it turns something many people did informally into something with a deadline attached. Below is what the statute asks for, when each piece started applying, and where the practical work actually falls.

Three separate photo requirements

It helps to stop thinking of this as one rule. AB 2801 added three, and they start on different dates and apply to different tenancies.

1. Move-out photos, before any work. Beginning April 1, 2025, take photographs within a reasonable time after the unit comes back to you — but *before* any repair or cleaning that you plan to deduct for. This one applies to every tenancy, no matter when it started.
2. Post-work photos. Photograph the unit again within a reasonable time after those repairs or cleanings are finished. Same start date, same universal application.
3. Move-in photos. For tenancies that begin on or after July 1, 2025, photograph the unit immediately before, or at the start of, the tenancy.

The photos have to reach the tenant

Taking the photographs is half of it. Under § 1950.5 you already had 21 days after the tenant hands the unit back to return the deposit or send an itemized statement of what you kept and why. AB 2801 added the photographs to what that statement must carry, alongside the bills, invoices, or receipts for the work.

You are not required to print them. The statute contemplates delivery by mail, by email, on a flash drive, or as a link to somewhere the tenant can view them. That is worth knowing before anyone spends an afternoon at a photo counter. We go through the whole packet in what has to go in the 21-day letter.

What is not covered here

AB 2801 also narrowed what you can charge a tenant for in the first place, which is a separate question from documenting it. Since January 1, 2025 you cannot require a tenant to pay for professional carpet cleaning — or other professional cleaning — unless it is reasonably necessary to return the unit to the condition it was in when the tenancy started, ordinary wear and tear aside. That deserves its own treatment: can you still charge a tenant for cleaning?

There is also a narrow exception to the photo requirements where the tenancy ended through certain unlawful detainer grounds under Code of Civil Procedure § 1161. Whether your situation falls inside it is exactly the sort of question to put to an attorney rather than a blog.

Where the work actually is

In practice the hard part is not the law, it is the sequence. The before photos have to happen after the tenant is out and before the cleaner arrives, which is usually the same 24 hours in which you are trying to get the unit turned around and re-listed. Miss that window and it cannot be recreated — the unit is already clean.

That is the whole reason we built a free move-out documentation tool. It walks you room by room, timestamps each photo against our server's clock rather than your phone's, and packages the before-and-after pairs with your itemized charges into one report you can send. It is a documentation aid — it organizes what you captured; it does not review your deductions or decide what you are entitled to keep.

If the turnaround itself is the problem, we also do move-in and move-out cleans across the Bay Area, and we can schedule the crew for after your before photos rather than before them.