Yes. California Civil Code section 1950.5 expressly contemplates repair or cleaning work performed by a landlord or the landlord's employee. When that work is deducted from the deposit, the itemized statement should reasonably describe the work and include the time spent and reasonable hourly rate. That documentation does not automatically validate the charge: the work must still fit an allowed deduction, be reasonably necessary, exclude ordinary wear, and be supported by the condition evidence.
Own labor is permitted, but a lump sum is not the statutory description
The statute distinguishes work by the landlord or an employee from work by an outside provider. For landlord or employee work, it calls for a reasonable description of the work, the time spent, and the reasonable hourly rate charged.
A label such as maintenance labor — $450 does not reveal the task, hours, or rate. Ask for those components without claiming that self-performed work can never be charged.
Recalculate the labor line
- Copy the exact labor description and amount from the statement.
- List each task, room, date, worker, and claimed hours.
- Multiply hours by the stated hourly rate and reconcile the total.
- Separate repair time, cleaning time, materials, travel, supervision, and overhead.
- Match each task to pre-work and post-work photographs.
- Flag duplicate labor already included in a contractor or materials charge.
Test whether the time and rate are reasonable
Section 1950.5 requires a reasonable hourly rate but does not publish one statewide rate card. Relevant audit evidence can include the complexity of the task, worker experience, local quotes for comparable work, contemporaneous time records, and whether the claimed hours include unrelated turnover work.
A professional contractor's retail rate is not automatically the proper rate for every owner task, and a landlord is not necessarily limited to minimum wage. Present comparable evidence and explain differences instead of asserting a number without support.
Check whether the work itself was deductible
Detailed time records do not answer whether the work addressed tenant-caused damage, reasonably necessary cleaning, ordinary wear, a preexisting defect, or routine turnover. Match the labor to the move-in condition, move-out condition, lease, inspection records, and photographs.
If a landlord painted an entire unit after patching one tenant-caused hole, separate the supported patching work from the broader painting scope. If cleaning restored a condition worse than at move-in, identify that evidence as well.
Request the missing calculation precisely
Ask for the task description, dates, time spent, hourly rate, materials records, and photographs for the named deduction. State whether you dispute the entire task or only the undocumented or excessive portion.
Self-performed work can be compensable, but the ultimate reasonableness of a disputed amount depends on the facts. A complete audit supports a focused discussion; it does not guarantee that the charge will be removed.
Clear answers before your next step.
Does the landlord need to create an invoice to charge their own labor?+
The statute focuses on the itemized statement reasonably describing the work and listing the time spent and reasonable hourly rate. A separate self-invoice is not the central statutory requirement.
Can a landlord charge a contractor's rate for personal labor?+
The rate must be reasonable for the work and circumstances. Comparable local rates may be evidence, but no single contractor rate automatically controls every landlord-performed task.
Can materials be added to an own-labor charge?+
Potentially, but materials and supplies have separate documentation requirements. Check bills, receipts, vendor records, quantity used, and whether the materials were necessary for the deductible work.
Official sources used for this guide
- California Civil Code § 1950.5
- California Courts security deposit guide
- California DRE 2026 tenant guide
This article provides general self-help information for California renters. It is not legal advice, does not create an attorney-client relationship, and does not predict the outcome of a dispute. Rules and local protections can change.
