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Housing · Warranty of habitability

Warranty of Habitability in Massachusetts

What a landlord in Massachusetts must keep livable, and your remedy when they do not: whether you can withhold or escrow rent, or must use another route. This is the landlord duty behind the repair-and-deduct remedy. Cited to the statute.

Confirmedagainst Boston Housing Authority v. Hemingway · established by case law; statute code checked for a superseding ruleReviewed by Cholilurrohman · July 2026
Warranty of habitability · Massachusetts
Massachusetts recognizes an implied warranty of habitability through Boston Housing Authority v. Hemingway, and the content of the standard is the State Sanitary Code at 105 CMR 410. It sets the most detailed heat rule in the country. The commonly-cited version is out of date, and the current rule runs the heating season from September 15 through May 31.
Case-law warranty, detailed heat code
Withhold rent?Case-law warranty, detailed heat code
Heat requirement68°F day / 64°F night, Sept 15–May 31
StatuteBoston Housing Authority v. Hemingway

What the warranty of habitability covers in Massachusetts

What the landlord must maintain, whether you can withhold or escrow rent, and the limits on the remedy.

What the law saysWhat it means
A warranty of habitability recognized by the courtsBoston Housing Authority v. Hemingway read an implied warranty of habitability into residential leases. The specific standards that fill in the warranty come from the State Sanitary Code, 105 CMR 410, "Minimum Standards of Fitness for Human Habitation," which runs directly against the owner.
The most detailed heat rule in the countryUnder 105 CMR 410.180 the owner must provide heat in every habitable room and every room with a toilet, shower or bathtub from September 15 through May 31, at least 68°F between 7:00 A.M. and 11:00 P.M. and at least 64°F between 11:01 P.M. and 6:59 A.M. The heating system may not push any room above 78°F. A board of health may shift the season’s edges by posting notice on the municipality’s website.
Heating equipment standardsSection 410.160 requires the owner to provide and maintain a heating system able to reach those temperatures, and it says a fireplace, a wood or pellet stove, and a portable electric space heater do not satisfy the requirement. Several unvented and portable heater types are prohibited outright.
Where it does not applyWhat it means
The season can be adjusted by the board of healthSection 410.180(D) lets a local board of health modify the heating season, ending it no earlier than May 15 or delaying its start no later than September 30, by posting notice on the municipality’s website. That posting route replaced the old requirement of a formal variance.
The old dates are supersededMany guides, and even a stale state guidance page, still cite 105 CMR 410.201 and a season of September 15 to June 15. The State Sanitary Code was reorganized effective May 12, 2023. The temperature rule moved to 410.180 and the season now ends about two weeks earlier, on May 31. Rely on the current rule, not the old citation.
Repair-and-deduct is tightly gatedUnder G.L. c. 111, s. 127L a tenant may repair or have repaired the conditions constituting violations and deduct up to four months’ rent in any twelve-month period, but only after the violation is certified by a board of health, a code agency or a court and written notice is given, and the owner then fails to act within the time the statute allows.
No federal habitability law
There is no national warranty of habitability. Whether a landlord must keep a rental livable, and what a tenant can do about a breach, is decided state by state. Massachusetts built the warranty through its courts and then gave it teeth through the State Sanitary Code.
Repair-and-deduct cannot be waived
G.L. c. 111, s. 127L says any lease provision by which a tenant waives the benefits of the section is against public policy and void. The repair-and-deduct cap is four months’ rent in any twelve-month period, and the section says it does not limit any other remedy the tenant has. The exact days a landlord has to begin and complete repairs come from an unconfirmed source and are not stated here.
No air conditioning requirement
Nothing in 105 CMR 410 requires air conditioning or cooling. The only cooling-adjacent sections address ventilation, and air conditioners appear only as optional owner-installed equipment. Massachusetts regulates heat in detail and does not regulate cooling.
In plain words
A quick key to the legal terms used on this page.
Implied warranty of habitability
A promise built into the lease, even when unwritten, that the landlord will keep the home fit to live in.

What you can do right now

Concrete, neutral steps when a rental in Massachusetts is not being kept livable. This is legal information, not legal advice.

  1. Get the violation certified

    The repair-and-deduct remedy in G.L. c. 111, s. 127L runs through an inspection. Ask your local board of health or code enforcement office to inspect and certify the violation, which is the trigger the statute requires.

  2. Put the defect in writing to the owner

    Give the owner written notice of the certified violation and keep a dated copy. Written notice plus the certification are what start the process, so document both.

  3. Track the temperatures during heating season

    From September 15 through May 31, the unit must reach 68°F by day and 64°F overnight. Log readings with a thermometer at times and places that match 105 CMR 410.180 if you think the heat falls short.

  4. Get Massachusetts tenant help before deducting

    Repair-and-deduct has strict conditions and a four-month cap. MassLegalHelp explains the certification and notice steps so you do not risk your tenancy by deducting the wrong way.

Tenant help in Massachusetts

Withholding rent the wrong way can risk eviction, so a legal aid office can confirm the exact notice and escrow steps before you stop paying.

MassLegalHelp (Housing)

This is general legal information, not legal advice. The notice, the escrow account, and what counts as uninhabitable all matter, so confirm your situation against the statute before withholding rent.

What renters in Massachusetts get wrong about habitability

Massachusetts has the most detailed heat rule in the country, and it is easy to get wrong because the commonly-cited version is out of date. The warranty of habitability itself is case law, from Boston Housing Authority v. Hemingway, but the content of the standard is the State Sanitary Code at 105 CMR 410, which runs directly against the owner. The heat rule, current at 105 CMR 410.180, requires the owner to provide heat in every habitable room and bathroom from September 15 through May 31, at least 68°F between 7:00 A.M. and 11:00 P.M. and at least 64°F overnight, with a ceiling of 78°F. Almost every guide, and even a stale state guidance page, still cites the old 410.201 and a season of September 15 to June 15. The Sanitary Code was reorganized effective May 12, 2023: the rule moved to 410.180 and the season now ends about two weeks earlier, on May 31, and a board of health can shift the edges by a website posting rather than a formal variance. The tenant remedy is repair-and-deduct under G.L. c. 111, s. 127L, capped at four months’ rent in a twelve-month period and gated behind an official certification of the violation. Nothing in the code requires air conditioning.

Common questions

Does Massachusetts have a warranty of habitability?

Yes. Boston Housing Authority v. Hemingway read an implied warranty of habitability into residential leases, and the specific standards come from the State Sanitary Code, 105 CMR 410. The code runs directly against the owner and covers heat, water, sanitation and structural fitness.

What is the required temperature in a Massachusetts apartment?

Under the current rule, 105 CMR 410.180, the owner must heat every habitable room and bathroom from September 15 through May 31 to at least 68°F between 7:00 A.M. and 11:00 P.M. and at least 64°F overnight, and no room may exceed 78°F. The older citation to 410.201 and a June 15 end date is superseded.

Can I repair and deduct in Massachusetts?

Yes, under G.L. c. 111, s. 127L, up to four months’ rent in any twelve-month period, but only after a board of health, code agency or court certifies the violation and you give the owner written notice and the owner then fails to act. The tenant’s right under the section cannot be waived by a lease.

Does a Massachusetts landlord have to provide air conditioning?

No. Nothing in 105 CMR 410 requires air conditioning or cooling. The code addresses ventilation and treats air conditioners as optional owner-installed equipment. Massachusetts regulates heat in great detail but does not regulate cooling.

Primary source
Boston Housing Authority v. Hemingway, 363 Mass. 184 (1973); 105 CMR 410.000; Mass. Gen. Laws ch. 111, § 127L
105 CMR 410 (Massachusetts State Sanitary Code) · mass.gov
Cholilurrohman
Every figure on this page is checked line-by-line against the current statute. Editorial standards →

Not legal advicePlainStatute provides plain-language summaries of public law for general information only. This is not legal advice. Statutes change; always confirm current requirements with the official source linked above before acting.

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