What should our HOA board do when the utility sends a disconnection notice for the association's own account?

By OurHOA · General information · Revised October 19, 2026

What an HOA board should do when the electric or water utility threatens to shut off common-area service: notice periods, disputes, paying, and telling owners.

Part of the HOA board handbook: treasurer and money.

The short answer

Treat the notice as an emergency with a short fuse, but not a hopeless one. Call the utility the day the notice arrives, confirm the amount and the shutoff date, and pay whatever part of the bill nobody disputes. If part of the bill is wrong, tell the utility in writing that you dispute it and, if it is a regulated company, file a complaint with the state commission. In Texas, Florida and Colorado, regulated utilities generally may not cut service over an amount that is under a pending dispute, though they can still demand the undisputed part. Then find out why it happened. In a self-managed HOA the cause is often paperwork, not a cash shortage: autopay tied to a closed bank account, bills going to a former treasurer's address, or an account still in the developer's name. Fix the cause the same week, or you will see the notice again. Rules depend on your state, the type of utility and your account class. This guide is education, not legal advice.

First 24 hours

One director owns this until it is fixed. Usually that is the treasurer, with the president as backup. Get the facts. Call the number on the notice and write down the account number, the account holder's name, the past-due amount, the shutoff date and the name of the person you spoke with. Ask what the account is: a streetlight circuit, the pool pump, the entry gate, the clubhouse, the irrigation meter or a master water meter. Check the books. Did the association pay and the payment fail? Did the bill go somewhere nobody reads? Did a vendor or the developer stop paying an account the association never knew it owned? Pay the undisputed amount by a method that posts fast, such as a phone or online payment from the operating account, and get a confirmation number. Many bylaws let the treasurer pay ordinary utility bills without a vote. If yours do not, the president can call a quick board vote by email where your state and documents allow it, and ratify it at the next meeting. Ask the utility to note the account so the shutoff order is cancelled, and confirm it in an email.

Notice periods and dispute rights by state

Florida. For utilities regulated by the Public Service Commission, Rule 25-6.105(5)(g) of the Florida Administrative Code requires at least five working days' written notice, separate from the bill, before an electric shutoff for nonpayment. Rule 25-30.320(2)(g) sets the same five working days for regulated water and wastewater companies, and that rule bars shutoffs on weekends and holidays for any customer. Under Rule 25-22.032(3), while a commission complaint is open, the company may not disconnect over the disputed amount, but it can require payment of the rest. Texas. Public Utility Commission Rule 25.29 sets the disconnection date at least 10 days after the notice is issued, never on a weekend or holiday, for electric utilities it covers. Rule 25.21 says those rules do not apply to municipal utilities. In the competitive market, Rule 25.483 sets the same 10-day minimum for retail electric providers and bars disconnection over disputed charges, except the amount not in dispute, until the dispute is resolved. The same rule treats medium and large non-residential accounts separately, so ask which class your account is in and read the contract. For PUC-regulated water and sewer utilities, Rule 24.167 requires a separate written notice with at least 10 days to act. Colorado. For electric utilities regulated by the Public Utilities Commission, 4 CCR 723-3 Rule 3408 requires written notice at least 12 business days before a shutoff, and Rule 3407 bars disconnection over an amount in a pending dispute or informal complaint, or for less than $50 past due. Rule 3400 limits these protections to residential, small commercial and agricultural customers as each utility's tariff defines them, so ask which class your common-area accounts fall in. City-owned utilities and many co-ops set their own rules by ordinance or bylaw. Ask for the shutoff policy in writing.

Disputing a bill without losing service

Put the dispute in writing the same day you pay the rest. One paragraph is enough: the account number, the charge you dispute, why, and the amount you are paying now. Keep proof it was sent. If the utility will not budge and it is regulated, file a complaint with the state commission. Florida lets any customer of a regulated company complain by phone or in writing. Colorado requires a regulated utility to tell an unhappy customer about the informal complaint process at the commission. Texas customers file with the Public Utility Commission. City utilities usually have an appeal to a billing office or the utility board instead. For a high water bill on a master meter, our guide on disputing a master-metered water bill with the utility covers meter tests and leak adjustments in detail.

Telling owners

Owners will notice a dark entry or a locked pool. Tell them before they notice. A short email or portal post works: "The association received a disconnection notice on the [pool / streetlight / irrigation] electric account on [date]. The cause was [a payment returned after our bank change / bills mailed to a former officer]. The balance was paid on [date] and the utility has confirmed service will continue. The board is moving all utility accounts to e-billing at the association's address so this cannot recur. Questions go to [treasurer email]." Keep it factual. Do not blame a named volunteer in writing. If service was actually cut, say what was affected, when it will be restored, and any safety steps, such as closing the pool until the pump and chlorinator run again.

Fix the cause

Make a list of every utility account the association pays: provider, account number, service address, what it powers, account holder name, billing address, payment method and typical monthly amount. Walk the property and match meters to accounts. Boards often find a meter nobody knew they had, or one the developer still pays. Put every account in the association's legal name with its tax ID, not a director's name. Send bills to an association email address that more than one officer can read. Use autopay from the operating account only if someone reviews the statement each month, and update every autopay the week you change banks. Add a second authorized contact on each account so the utility will talk to someone when the treasurer is away. Our new HOA treasurer handoff checklist includes the utility list, so the next turnover does not lose an account.

Mistakes boards make

Ignoring the envelope. Shutoff notices go out separately from the bill, and a separate envelope to an old address sits unopened. Paying nothing while disputing everything. A regulated utility can still shut off for the undisputed part. Waiting for the next board meeting. The notice period is days, not weeks. Calling with no authority. Many utilities will only discuss an account with the named holder or an authorized contact. Fix that before you need it. Assuming the developer pays. After turnover, accounts left in the builder's name can go delinquent the day they stop paying, with the association's lights on the line.

Sources

These guides are general education for HOA boards and residents, not legal, tax, or financial advice. Rules vary by state and by your community's governing documents - check with a professional for your situation.

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