California Creates Single-Commissioner Property Tax Appeals Process

This update highlights recent developments affecting commercial property taxation in California. It reflects analysis prepared by an APTC member firm based on conditions at the time of publication.

In September 2026, California enacted Assembly Bill 2172, authorizing counties with populations of 500,000 or more to allow certain property tax appeals to be heard by a single Assessment Appeals Commissioner rather than a traditional three-member Assessment Appeals Board panel. Beginning January 1, 2027, counties may adopt the commissioner model by ordinance as an alternative method for resolving assessment disputes. The legislation was intended to address growing appeal backlogs and increasing valuation complexity in larger counties, particularly with respect to income-producing and commercial properties. Importantly, taxpayers retain the right to object to commissioner review and have their appeal heard by a traditional assessment appeals board instead. The new law is especially noteworthy because it introduces a potentially faster path for resolving property tax appeals while preserving taxpayers’ ability to have disputes heard by a traditional multi-member appeals board, a change that may significantly impact the administration of high-value and complex assessment appeals in California’s larger counties.

Cris O'Neall and Bree Burdick
Greenberg Traurig, LLP
Member Firm, American Property Tax Counsel

For guidance on how these developments may apply to your property or portfolio, please contact the APTC representative listed above.