Year-End Compliance Report: Are You AB 628 Ready for 2027?

We're closing the books on 2026. and with it, the first full year of AB 628 as law in California. If you manage rental properties in this state, December is the time to ask one hard question: Are you actually compliant?

Not "probably fine." Not "no issues yet." But: do you have a documented, auditable system proving you've monitored appliance recalls, notified tenants, and remediated within the 30-day statutory window. for every unit, all year?

If the answer is anything less than a confident yes, this is your roadmap. Here's what AB 628's first year taught us, the recalls that caught PMs off guard, a 10-item year-end audit checklist, and how to budget for a compliant 2027.

1. AB 628's First Year: What We Learned

AB 628 went into effect January 1, 2026, amending Civil Code §1941.1 to make functioning stoves and refrigerators a statutory habitability requirement. with a 30-day remediation deadline on every recalled appliance in a California rental unit. Twelve months in, three things are clear:

Recalls Didn't Slow Down

The CPSC issued 376 consumer product recalls in 2025, and 2026 is trending at a similar pace. The compliance obligation isn't a one-time exercise. it's an ongoing, year-round monitoring requirement that doesn't take holidays.

Tenant Attorneys Are Using AB 628

Throughout 2026, tenant-side attorneys have started citing AB 628 directly in habitability cases. It gives them a clean statutory hook: a recalled appliance that wasn't remediated within 30 days is a per-se habitability violation. no need to prove the appliance was actually dangerous. We've seen AB 628 in demand letters, habitability complaints, and lease termination disputes. It's no longer theoretical. it's an active litigation tool.

"Constructive Knowledge" Is Being Tested

The most consequential development: courts are applying the constructive knowledge doctrine to AB 628. Does your 30-day clock start when the CPSC publishes a recall, or when you personally learn about it? Early signals point toward the publication date. the CPSC database is a public record, and professional PMs have a duty to monitor it.

2. 2026 Recall Stats Recap

In 2026, the CPSC issued approximately 80 appliance-specific recalls covering ranges, refrigerators, dishwashers, microwaves, air conditioners, and portable appliances commonly found in rental units. Three that every California PM should know:

Samsung Electric & Gas Ranges (CPSC #24-335)

Samsung ranges are a recurring concern. and CPSC #24-335 is one of the most significant for PMs. High-volume brand, common in multi-family housing, fire and burn hazard. If you have Samsung ranges and weren't monitoring, you may have had affected units without knowing. As the Samsung recall case study shows, financial exposure can reach $65,000 per incident.

AstroAI Mini-Fridges (249,000 Units)

Recalled for fire and burn hazards, these 249,000 units were sold primarily online. inexpensive, often purchased by tenants, and rarely tracked in PM systems. If your leases don't include tenant-provided appliance addendums, you may still carry liability.

Midea Window Air Conditioners (1.7 Million Units)

The big one. Midea manufactured 1.7 million window ACs sold under the Frigidaire, Danby, and Keystone brand names. some of the most common window AC brands in California rentals. The recall covers units sold between 2020–2024 due to fire hazard from overheating.

This is a textbook case for automated recall tracking. The units weren't sold under the Midea name. A PM searching for "Midea" wouldn't find their Frigidaire units. You need model-number-level matching, not brand-name awareness.

3. Your Year-End AB 628 Audit Checklist

Whether you've been monitoring all year or you're catching up before the new year, here are the 10 items every California property manager should complete before December 31. Print this list, assign owners, and check off each item:

1. Complete your appliance inventory Record the manufacturer, model number, and serial number for every landlord-provided appliance in every unit. If you don't have this inventory, you can't check for recalls. and you can't prove compliance.
2. Run a full portfolio recall scan Cross-reference your complete appliance inventory against the current CPSC recall database. Every model number, every unit. Don't skip "older" appliances. recalls can be issued for products sold years ago.
3. Resolve outstanding recalled appliances For any recalls identified, document the remediation: repair completed (with OEM confirmation), replacement installed, or recall remedy applied. Keep invoices, work orders, and manufacturer correspondence.
4. Verify tenant notification records For every recall discovered this year, confirm you have documentation of tenant notification. when they were informed, how, and what action was taken. This is critical if a tenant later claims they weren't told.
5. Confirm your ongoing monitoring system is active A one-time check in December doesn't satisfy AB 628's constructive knowledge standard. You need continuous monitoring. not quarterly, not "when I remember." Verify your system (automated or manual) will keep running into 2027.
6. Review lease addendums for tenant-provided appliances AB 628 includes an exception for appliances the tenant provides via a signed written addendum. Review your leases: if a tenant brought their own fridge or range, is the addendum in place? If not, your standard AB 628 obligations apply.
7. Train (or retrain) maintenance staff on recall identification Your maintenance team is your first line of defense. They're in units every week. Can they identify a recalled appliance? Do they know what to do when they spot one? Schedule a refresher before year-end.
8. Generate RecallCert documentation for all properties Create a compliance snapshot for every property in your portfolio. a dated record showing what was checked, what was found, and what was remediated. This is your audit trail if you ever need to demonstrate compliance.
9. Budget for recall compliance in 2027 operating expenses Compliance costs money. whether it's staff time, software, or appliance replacements. Build it into your 2027 operating budget now, not as an afterthought in Q2. (More on budgeting below.)
10. Schedule your Q1 2027 compliance review Don't wait until next December. Put a Q1 review on the calendar. January or February. to verify monitoring is running, catch any recalls issued over the holidays, and address any gaps before they become problems.

4. What's Coming in 2027

AB 628 was the first domino. Here's what to watch for in 2027:

Other States Are Watching California

New York, Massachusetts, New Jersey, and Illinois all have broad implied warranty of habitability statutes. None have passed an AB 628 equivalent yet, but California is the bellwether for tenant protection law. With AB 628 generating case law, other states have a blueprint. Multi-state PMs should prepare for similar legislation by 2028.

Insurance Carriers Are Tightening Requirements

Insurance carriers are already asking about recall compliance documentation during underwriting. Expect this to intensify in 2027. A recalled appliance is a known, documented hazard. and a landlord who ignores it is a higher risk. Verifiable monitoring documentation may become a condition of favorable rates or even coverage.

PM Software Is Late to the Game

Major PM platforms are mentioning recall features in their roadmaps. but enterprise software moves slowly. Realistic ship dates are 12–18 months out, with reliability even further behind. Don't leave a compliance gap while waiting for a feature update. The reality of PM software recall gaps means you need a purpose-built solution now.

First Appellate Decisions May Arrive

Cases filed in early 2026 are working through the courts. The first appellate decisions. setting binding precedent on constructive knowledge, the 30-day timeline, and damages. could arrive in 2027. Smart PMs will already be compliant. Those who aren't may find the decisions eliminate whatever ambiguity they were relying on.

5. Budgeting for Compliance

Year-end means budgets. If you're building your 2027 operating plan, here's how to think about recall compliance costs:

RecallProof Pricing (for reference)

Annual billing saves 20%. For a 500-unit portfolio on Professional: ~$1,000/month or $9,600/year with the annual discount.

Compare that to one Samsung-style incident: $65,000+ in combined exposure from rent abatement, repair-and-deduct, retaliation damages, and tort liability. That's nearly 7 years of RecallProof coverage wiped out by one incident. Budget it as insurance, not software. because that's what it is. Landlord insurance won't cover negligence when you knew about a recall. RecallProof's $1M Total Coverage Guarantee does.

6. The PMs Who Are Ahead

Not every PM spent 2026 scrambling. Those who implemented automated monitoring early caught recalls in real time, documented compliance for every unit, and generated OEM reimbursement claims that turned compliance into a cost-neutral activity. Several have used RecallCert documentation to dismiss habitability claims outright.

These managers have a complete appliance inventory, continuous monitoring, and a compliance trail that satisfies any court or insurance auditor. They're heading into 2027 protected.

The managers who are worried? The ones doing compliance manually with spreadsheets and quarterly CPSC checks. now discovering in December that they had Frigidaire window ACs in 40 units and didn't know those were recalled Midea units.

7. Start 2027 Protected

Don't enter 2027 with the same compliance gap you had in 2026.

Whether you use RecallProof or build your own process, the checklist above is your minimum standard. Complete it before December 31. Assign accountability. Document everything.

But be honest about what manual compliance actually costs. Weekly CPSC checks, inventory management, model-number cross-referencing, tenant notifications, remediation tracking, documentation. that's approximately $2,500/year in labor for a mid-size portfolio. And it still leaves gaps. Manual processes don't catch recalls in real time, don't flag model numbers sold under different brands, don't generate court-ready documentation, and don't scale.

For $9,600/year (500 units, annual billing), RecallProof eliminates every gap. plus gives you the $1M Total Coverage Guarantee.

2027 is four weeks away. The recalls aren't slowing down. The courts aren't backing off. The tenant attorneys are getting sharper. And the constructive knowledge clock is always ticking. Get compliant now.