St. Paul's Residential Rent Stabilization Ordinance has changed significantly since voters approved it in 2021. Property managers who still operate based on the original 3% rent cap without understanding the exemptions, exception pathways, and the May 2025 amendments that permanently exempted buildings first occupied after December 31, 2004 are working from an incomplete picture of the current framework.

This guide explains which properties are covered, which are exempt, what each exception pathway requires, and what compliance looks like under the ordinance as amended through June 13, 2025.

St. Paul's Residential Rent Stabilization Ordinance under Chapter 193A of the St. Paul Legislative Code limits residential rent increases to no more than 3% in any 12-month period for covered properties. The ordinance was approved by voters in November 2021, amended by the City Council in September 2022 (effective January 1, 2023), and amended again in May 2025 (effective June 13, 2025). The May 2025 amendment permanently exempted all residential rental properties with a first certificate of occupancy issued after December 31, 2004. Covered properties are those with a first certificate of occupancy on or before December 31, 2004. Enforcement is administered by the Department of Safety and Inspections.

St. Paul Rent Stabilization at a Glance

Here is what this guide covers:

1. The history and current state of the ordinance

2. Which properties are covered

3. Which properties are exempt

4. The 3% standard allowable increase

5. The self-certification exception (3% to 8%)

6. Partial vacancy decontrol after just cause vacancy

7. The reasonable return on investment exception

8. The application and tenant notification process

9. Enforcement and penalties

10. What property managers must have in place

The History and Current State of the Ordinance

Understanding how St. Paul's rent stabilization ordinance arrived at its current form matters operationally because the framework has changed significantly three times in four years and property managers who have not tracked those changes are likely working from outdated assumptions.

Voters approved the original ordinance in November 2021 by a margin of 53% to 47%. The original text imposed a 3% annual cap with no exemptions and no vacancy decontrol. It was one of the most restrictive rent stabilization measures enacted in the United States at the time of passage. The ordinance took effect May 1, 2022.

In September 2022, facing significant pressure from housing developers who argued the ordinance was suppressing new construction, the City Council amended the ordinance to add a 20-year new construction exemption, an affordable housing exemption, a partial vacancy decontrol provision allowing CPI plus 8% increases after qualifying vacancies, a self-certification exception pathway, and a reasonable return on investment exception process. These amendments took effect January 1, 2023.

The City Council voted 4 to 3 on May 7, 2025 to replace the 20-year rolling new construction exemption with a permanent fixed-date exemption: all residential rental properties with a first certificate of occupancy issued after December 31, 2004 are now permanently exempt from the ordinance. The May 2025 amendment that permanently exempted post-2004 buildings was a significant contraction of the ordinance's coverage, responding to concerns from developers and the mayor that the ordinance was suppressing new housing construction in the city. This amendment took effect June 13, 2025.

St. Paul remains the only city in Minnesota with a rent stabilization ordinance. Minnesota does not have a statewide ban on local rent control ordinances, but it also does not have a statewide rent control law.

Which Properties Are Covered

The ordinance covers residential rental properties in St. Paul with a first certificate of occupancy issued on or before December 31, 2004. The coverage is broad within that threshold. Single-family homes rented to tenants, duplexes, multi-unit apartment buildings, and condominiums rented as residential units are all covered if the first certificate of occupancy was issued on or before that date.

The ordinance applies regardless of the number of units in a building. There is no minimum unit count below which a property is exempt. A landlord who rents a single-family home built before 2005 in St. Paul is subject to the ordinance. A management company managing a portfolio of older apartment buildings across the city is subject to the ordinance on every property that meets the construction date threshold.

The first certificate of occupancy date, not the current owner's purchase date or the current tenant's lease start date, determines coverage. A building constructed in 1995 that was sold in 2022 is covered. The transaction date does not affect coverage status.

Which Properties Are Exempt

The May 2025 amendment created a permanent fixed-date exemption that now covers a meaningful portion of St. Paul's rental housing stock. The following categories are currently exempt from the ordinance:

New construction exemption: All residential rental properties issued their first building certificate of occupancy after December 31, 2004 are permanently exempt. This includes both ground-up new construction and formerly non-residential properties converted to residential use that received a new or renewed certificate of occupancy for residential use after December 31, 2004.

Property managers cannot independently look up a building's first certificate of occupancy date. That information is held by the Department of Safety and Inspections. Owners who believe their property qualifies for the new construction exemption should contact DSI and request a certificate of occupancy verification. DSI will provide a letter confirming the date and the property's exemption status. Operating on the assumption of an exemption without confirming it with DSI creates enforcement exposure.

Low-income housing provider exemption: Affordable housing properties whose rents are already regulated through a government agreement with the landlord are exempt. This covers properties subject to Low Income Housing Tax Credit agreements, project-based Section 8 contracts, and similar government-regulated affordability commitments.

Building demolitions and conversions: Properties being demolished or converted to non-residential use are exempt. Properties being converted to condominiums or cooperatives may qualify for exemption, but specific documentation requirements apply including recording the condominium declaration with Ramsey County.

Exempt landlords must notify prospective tenants that the rental unit is not subject to the ordinance. DSI recommends obtaining a written exemption letter from the department for documentation purposes.

The 3% Standard Allowable Increase

For covered properties, the standard maximum rent increase is 3% in any 12-month period. This increase does not require city approval, notification to DSI, or any application process. A landlord who wishes to raise rent by 3% or less may do so by providing the tenant with proper written notice under applicable Minnesota landlord-tenant law.

The 12-month period is measured from the date of the last rent increase, not from the beginning of the lease term or the lease anniversary date. A landlord who last raised rent in March 2025 cannot raise rent again until March 2026. A landlord who skips a year without raising rent does not automatically accumulate the right to a 6% increase the following year. The 12-month clock runs from the date of the last actual increase.

The 3% cap applies to the current rent amount, not the original lease amount. If monthly rent is $1,200, the maximum 3% increase is $36, bringing the new rent to $1,236.

Late fees are not considered rent under the ordinance and are not subject to the 3% cap. A landlord may implement or modify late fee provisions independently of the rent stabilization framework.

The Self-Certification Exception (3% to 8%)

For landlords who need to increase rent above 3% but below 8%, the self-certification exception provides a streamlined pathway that does not require full financial documentation or a staff determination process.

Under the self-certification pathway, landlords may increase rent between 3% and 8% by self-certifying certain conditions to DSI. The self-certification process is evaluated annually by DSI, and the specific conditions and documentation required are detailed on the DSI Rules and Processes page. This pathway is designed for situations where modest increases above the standard limit are needed without requiring the full reasonable return on investment analysis.

When a landlord submits a self-certification application, DSI notifies the tenant. The tenant has 45 days from DSI's determination to file an appeal with the legislative hearing officer if they believe the increase is not justified or the self-certification conditions were not met.

For property managers managing older buildings with significant operating cost increases but without the documentation overhead that a full RROI application requires, the self-certification pathway is the most operationally practical exception route for modest above-cap increases.

Partial Vacancy Decontrol After Just Cause Vacancy

The partial vacancy decontrol provision, added in the September 2022 amendments, allows landlords to increase rent by up to CPI plus 8% when a unit becomes vacant for a qualifying just cause reason. This is the most significant exception available to property managers managing occupied buildings where tenants have been in place for extended periods at below-market rates.

A just cause vacancy is one where the tenant chose not to renew their lease or was removed for qualifying violations including nonpayment of rent or material lease breach. Not all vacancies qualify. A vacancy resulting from a landlord-initiated no-fault termination, an owner move-in, or a unit becoming uninhabitable due to needed renovations is not a just cause vacancy for purposes of the decontrol provision.

To take advantage of partial vacancy decontrol, the landlord must submit an application to DSI demonstrating that the vacancy was a just cause vacancy. DSI reviews the application, notifies the prior tenant if applicable, and makes a determination. The landlord may then increase rent by CPI plus 8% based on the calculation applicable at the time of the increase.

The partial decontrol provision also incorporates a banking mechanism. If a landlord has not applied previous allowable 3% increases, the ordinance allows those banked increases to be applied in connection with a just cause vacancy decontrol request. The interaction between banked increases and vacancy decontrol is complex and the specific calculation methodology is addressed in DSI's rules and processes documentation.

Property managers who acquire buildings where previous owners did not raise rents for several years may have accumulated banking credit that becomes valuable in a vacancy decontrol context. Understanding the banked increase position for each covered unit is part of effective portfolio management under the ordinance.

RIOO's leasing management tools support the rent increase tracking, tenant notice documentation, and lease management workflows that St. Paul's rent stabilization compliance requires across covered portfolios.

The Reasonable Return on Investment Exception

The reasonable return on investment exception is the most comprehensive exception pathway and the one with no cap on the resulting increase. A landlord who can demonstrate through financial documentation that the 3% standard increase is insufficient to achieve a reasonable return on investment may petition DSI for approval of a higher increase.

DSI evaluates RROI petitions using nine statutory factors set out in Chapter 193A.06 of the ordinance, including the landlord's operating costs, capital improvement expenses, debt service, vacancy rates, and the condition of the property. DSI has developed specific rules for how capital improvements are amortized and how each factor is weighted in the analysis.

The RROI process requires detailed financial documentation and is more time-consuming than the self-certification pathway. For property managers managing buildings with significant deferred maintenance, recent capital improvements, or cost structures that cannot be sustained under the standard cap, the RROI process is the appropriate pathway.

Both landlords and tenants have 45 days from DSI's determination on an RROI application to file an appeal with the legislative hearing officer. This appeal right applies to all exception pathways, not only RROI petitions.

The Application and Tenant Notification Process

For any exception above 3%, the landlord must submit an application to DSI. The application form is available on DSI's website. When an application is submitted, DSI notifies affected tenants by mail. Tenants are informed when the application is received and when a determination is made.

The notification requirement is operationally significant. Tenants who receive notice of a landlord's exception application have 45 days from DSI's determination to appeal. A landlord who implements an increase above 3% without going through the exception process, or who implements the increase before DSI approves it, has violated the ordinance and is exposed to enforcement action.

DSI's approval or denial of exception applications is reviewable by the legislative hearing officer. Either the landlord or the tenant may appeal. The appeal must be filed within 45 days of DSI's determination.

Enforcement and Penalties

The ordinance is enforced by the Department of Safety and Inspections. Tenants who believe their landlord has violated the ordinance by increasing rent above the allowable limit without following the required exception process may file a complaint with DSI.

DSI investigates complaints and has authority to order corrective action including requiring the landlord to reduce rent to the allowable level and to reimburse tenants for overcharges. The ordinance creates enforcement exposure for landlords who implement above-cap increases without DSI approval, who fail to notify tenants of exception applications, or who misrepresent exemption status.

Landlords who believe their property is exempt but have not confirmed that exemption with DSI are in a vulnerable position if a tenant files a complaint. An informal understanding that a building was constructed after 2004 without a DSI-issued confirmation letter does not protect the landlord if the first certificate of occupancy date is disputed.

For context on how just cause eviction frameworks operate at the state level in comparable markets, see RIOO guide to Washington's just cause eviction law

What Property Managers Must Have in Place

Confirmed exemption status for every property in the portfolio. The first step for any St. Paul property management operation is confirming whether each property is covered or exempt. For properties with first certificates of occupancy issued after December 31, 2004, that exemption should be confirmed in writing from DSI. For all other properties, covered status should be assumed until verified.

A 12-month rent increase tracking system by unit. The 3% cap applies per 12-month period measured from the date of the last increase, not from the lease anniversary date. Property managers must track the last increase date for each covered unit individually. A portfolio-wide annual rent review process that does not account for unit-by-unit increase dates will produce compliance errors.

A banked increase record for each covered unit. If a property has been owned or managed without applying the full 3% increase in prior years, the banked increase credit may be available in certain exception pathways. Knowing the banked position for each unit is relevant to exception planning, particularly for vacancy decontrol applications.

Familiarity with just cause vacancy requirements before processing a vacancy. When a unit in a covered building becomes vacant, the first question is whether the vacancy qualifies as just cause for purposes of the CPI plus 8% decontrol provision. This determination must be made before setting the new rent, not after. A landlord who sets a new rent above 3% on the assumption of just cause without confirming the vacancy qualifies, and without DSI approval, has an unauthorized increase.

A DSI application workflow for any increase above 3%. Any rent increase above 3% on a covered property requires an application to DSI before the increase is implemented. This cannot be done retroactively. Property managers should treat the DSI application as a prerequisite step in the rent increase workflow, not a post-increase formality.

Key Takeaways for Property Managers

• St. Paul's Residential Rent Stabilization Ordinance under Chapter 193A limits rent increases to 3% per 12-month period for covered residential rental properties. The ordinance has been amended in September 2022 and May 2025 and the current framework reflects both sets of amendments

• As of June 13, 2025, all residential rental properties with a first certificate of occupancy issued after December 31, 2004 are permanently exempt. Exempt landlords must notify prospective tenants of exempt status and are encouraged to obtain a written confirmation letter from DSI

• Covered properties are those with a first certificate of occupancy on or before December 31, 2004. Coverage applies regardless of unit count and includes single-family rentals, duplexes, and multi-unit buildings

• Three exception pathways exist for above-cap increases: self-certification (3% to 8%), partial vacancy decontrol after just cause vacancy (CPI plus 8%), and reasonable return on investment petition (no cap). All require DSI application and approval before implementation

• When any exception application is submitted, DSI notifies the tenant. Both parties have 45 days from DSI's determination to file an appeal with the legislative hearing officer

• The 3% standard cap applies per 12-month period measured from the date of the last rent increase, not from the lease anniversary. Each covered unit must be tracked individually

• Landlords who implement above-cap increases without DSI approval are subject to enforcement action including required rent reduction and reimbursement of overcharges

• St. Paul is the only city in Minnesota with a rent stabilization ordinance. Minnesota does not have statewide rent control

The Ordinance Has Changed Significantly and Will Likely Continue to Evolve

The St. Paul Rent Stabilization Ordinance that property managers must comply with today is not the ordinance voters approved in November 2021. It has been amended twice by the City Council, each time in response to real-world evidence about the ordinance's impact on housing development and investment.

The most reliable source for current requirements is the DSI rent stabilization page at stpaul.gov. Property managers operating in St. Paul should treat that page as a compliance reference, not a one-time resource. The ordinance has been amended three times in four years and the regulatory environment for St. Paul rent stabilization remains active.

Property managers who know which of their properties are covered, which are exempt, what exception pathways are available, and what the DSI application process requires for above-cap increases can operate within this framework without compliance exposure. Those who operate on outdated assumptions about the ordinance's coverage or exception availability will find enforcement consequences arrive at the worst possible time.

FAQ

1. What is St. Paul's Rent Stabilization Ordinance?
Chapter 193A of the St. Paul Legislative Code, approved by voters in November 2021 and amended in September 2022 and May 2025. It limits rent increases for covered residential rental properties to no more than 3% in any 12-month period, with exception pathways available for increases above that limit.

2. Which properties are covered by St. Paul's rent stabilization ordinance?
Residential rental properties with a first certificate of occupancy issued on or before December 31, 2004. This includes single-family rentals, duplexes, and multi-unit apartment buildings. Properties with a first certificate of occupancy issued after December 31, 2004 are permanently exempt under the May 2025 amendment.

3. How do I know if my building is exempt from the St. Paul rent stabilization ordinance?
Contact the Department of Safety and Inspections to request a certificate of occupancy verification. DSI will confirm the date and issue a letter indicating exemption status. Property managers cannot independently look up this information through public records.

4. Can a St. Paul landlord raise rent by more than 3%?
Yes, through three exception pathways. Self-certification allows increases from 3% to 8% annually. Partial vacancy decontrol allows CPI plus 8% after a qualifying just cause vacancy. A reasonable return on investment petition allows increases above any cap when financial documentation supports the need. All three require DSI application and approval before implementation.

5. What is a just cause vacancy under St. Paul's ordinance?
A vacancy where the tenant chose not to renew their lease or was removed for qualifying violations such as nonpayment of rent or material lease breach. Not all vacancies qualify. Vacancies resulting from landlord-initiated no-fault terminations generally do not qualify as just cause for partial vacancy decontrol purposes.

6. How does the 12-month period work for the 3% cap?
The 12-month period is measured from the date of the last rent increase, not from the lease anniversary date. A landlord who increased rent in March 2025 cannot increase rent again until March 2026 regardless of when the lease term began or renewed.

7. What happens if a landlord increases rent above 3% without DSI approval?
The increase is a violation of the ordinance. DSI may order the landlord to reduce rent to the allowable level and to reimburse tenants for any overcharges collected. Tenants may file complaints with DSI triggering an enforcement investigation.

The information in this article reflects St. Paul's Residential Rent Stabilization Ordinance under Chapter 193A of the St. Paul Legislative Code as amended through June 13, 2025, and as of 2026. The ordinance has been amended multiple times since its original passage and may be amended again. Property managers should verify current requirements directly with the Department of Safety and Inspections and consult qualified Minnesota legal counsel before making compliance decisions for any specific property or situation.