Northland Investment Corp. v. PURA upheld the conclusion that a landlord may not recoup master-meter building-wide utility costs through estimated proportionate RUB shares.
The current statute excepts service furnished to a dwelling unit on an individually metered or billed basis for the exclusive use of the occupants of that unit.
Approved submetering is subject to the state framework, customer-class rate limits and protections against charging common-area or other nonexclusive usage to the submetered account.
PA 26-113 applies to rental agreements entered into or renewed on or after October 1, 2026 and requires a separate meter for utilities the lease makes the tenant pay.
Start by identifying whether the building is master metered
If the utility provider sends one building-level bill and the landlord or billing company then allocates a variable monthly share to each apartment using occupants, bedrooms, square footage or another formula, the billing model may resemble the RUB method reviewed in Northland.
Preserve the provider/master bill if available, the tenant statement and the utility addendum showing the allocation method. The legal question is different from a direct utility account or an approved submeter that measures only the unit’s use.
Connecticut’s 2024 Supreme Court decision is a major RUB checkpoint
In Northland Investment Corp. v. Public Utilities Regulatory Authority, the Connecticut Supreme Court upheld PURA’s determination that §16-262e(c) precludes the proposed use of ratio utility billing to recoup building-wide master-meter utility costs from tenants through estimated proportionate shares.
The opinion distinguished that monthly variable recoupment from a landlord estimating annual utility costs in advance and building that estimate into fixed rent. Do not treat the decision as a general ban on every utility amount associated with rent; identify the billing model first.
Individual metering or billing must match exclusive unit use
Section 16-262e(c) places covered building utility costs on the owner/landlord except for service furnished to a dwelling unit on an individually metered or billed basis for the exclusive use of that unit’s occupants.
A practical evidence question is therefore what the meter or billing account actually serves. If it includes common areas or other units, document that before assuming the statement represents only the tenant’s own usage.
Submetering has a separate PURA framework
Connecticut law allows submetering in specified settings and other PURA-approved locations. The PURA consumer FAQ says regulated water/electric submetering requires prior approval for the location.
For approved electric submetering, §16-19ff limits the rate to no greater than the applicable customer-class rate and does not permit the submetered account to be charged for common-area usage or other usage not solely for that account.
A new lease rule begins October 1, 2026
Public Act 26-113 is enacted but is not yet effective on September 1, 2026. Beginning October 1, 2026, it applies to rental agreements entered into or renewed on or after that date and prohibits a lease term requiring the tenant to pay utilities when there is no separate meter measuring utilities delivered exclusively to the dwelling unit.
For a bill or lease spanning the effective date, record when the rental agreement was entered into or renewed rather than applying the October rule automatically to an earlier agreement.
Records worth gathering for a Connecticut utility dispute
- Current and prior tenant utility statements.
- Lease and utility/RUB/submetering addendum.
- Underlying provider or master bill, if available.
- Meter or submeter identifier and what areas it serves.
- PURA approval/docket information if the property says it uses regulated submetering.
- Calculation showing how the tenant amount was derived.
- Date the rental agreement was entered into or renewed, especially around October 1, 2026.
Compare this topic across states
Official sources
Current Connecticut utility statute making the residential property owner/landlord liable for covered building utility costs except service furnished to a dwelling unit on an individually metered or billed basis for the exclusive use of that unit’s occupants.
Connecticut Judicial BranchNorthland Investment Corp. v. PURA, 349 Conn. 35 (2024) ↗Official Connecticut Supreme Court opinion holding that §16-262e(c) precludes the proposed use of ratio utility billing to recoup master-meter building-wide utility costs through tenants’ estimated proportionate shares.
Connecticut General AssemblyConn. Gen. Stat. § 16-19ff — Submetering ↗Current submetering framework requiring PURA approval for covered locations and limiting approved electric submeter charges to the applicable customer-class rate while excluding common-area or other nonexclusive usage from a submetered account.
Connecticut Public Utilities Regulatory AuthorityPURA Consumer FAQ — Residential submetering ↗Current official consumer guidance explaining that water/electric submetering regulated by PURA requires prior approval for the location and that a landlord or management-company bill may indicate a submetering arrangement.
Connecticut General AssemblyPublic Act 26-113 — Utility charges for residential dwelling units ↗Enacted 2026 law effective October 1, 2026 for rental agreements entered into or renewed on or after that date; it adds a prohibited lease term requiring a tenant to pay utilities without a separate meter measuring utilities delivered exclusively to the dwelling unit.