Despite the recent passage of the RENTAL Act (D.C. Law No. L26-0080; effective December 31, 2025) and its ostensible intent to rebalance rights of both housing providers and tenants, the District of Columbia City Council (the “Council”) enacted new legislation which imposes more regulatory requirements on housing accommodations exempt from rent stabilization.
On March 3, 2026, the Council passed emergency legislation entitled the “Rental Housing Registration Data Integrity Emergency Amendment Act of 2026” (Bill 26-0610) (the “Emergency Act”) to mandate that the owner of a rental accommodation that is exempt from rent control under D.C. Code §42-3502.05(a) must, at the time of registration, provide the following information for each rental unit: (a) the current monthly rent amount; (b) the monthly rent amount charge for the same unit during each of the 2 prior calendar years; and (c) the utilities, facilities and services, and appliances. The Emergency Act expressly provides that the information is only required at time of registration (e.g., the filing of the Claim of Exemption with the Rental Accommodations Division) and is not subject to any ongoing or annual reporting requirements.
As most housing providers registered or re-registered their housing accommodations through the Department of Housing and Community Development’s new Rent Registry database prior to the enactment of the Emergency Act and as there is no language in the Emergency Act making the registration requirement retroactive, the Emergency Act will only impact properties exempt from rent stabilization that (i) have yet to be registered or re-registered on the Rent Registry; or (ii) upon future registration (e.g., newly constructed housing accommodation; sale of a housing accommodation with the new owner eligible to claim an exemption from rent control).
The Emergency Act took effect on March 25, 2026, and is effective through June 23, 2026 (emergency legislation is effective for no more than 90 days from mayoral approval or, in the event of a mayoral veto, a successful Council override vote).
We note that concurrently with the introduction of the Emergency Act, the Council introduced the “Rental Housing Registration Data Integrity Temporary Amendment Act of 2026” (Bill 26-0611) (the “Temporary Act”). The Temporary Act passed the first reading 13-0 but requires a second reading with a favorable vote before transmission for mayoral review. Assuming mayoral approval or Council override of a mayoral veto, the Temporary Act next undergoes a 30-day congressional review period. The Temporary Act will be effective for no more than 225 days following mayoral approval or, in the event of a mayoral veto, action by the Council to override the veto, and expiration of the subsequent congressional review period. Interestingly, there is no related permanent legislation pending before the Council, but permanent legislation may be introduced later.
Should you have any questions about this matter, please contact Richard W. Luchs (rwl@gdllaw.com), Joshua M. Greenberg (jmg@gdllaw.com) or Phil Blackmon, Jr. (prb@gdllaw.com).
