San Francisco's Property Tax Appeals Have Outgrown the Office That Hears Them
Summary
San Francisco has $281.6 billion in assessed property value tied up in 14,652 open tax appeals as of January 2026, and a refund reserve the Controller's Office has built to $431.0 million. The Board of Supervisors' own salary ordinance shows the entire net staffing increase for the Assessor-Recorder's appraisal corps this year was three-quarters of one position.
Follow the dollar
San Francisco doesn't wait for the Assessment Appeals Board (AAB) to rule before it starts protecting itself. Every year, the Controller's Office holds back a slice of current property tax revenue and deposits it into a reserve earmarked for refunds the city expects to eventually owe. This fiscal year that slice is $105.2 million — money collected, but not available to spend on anything else — which brings the accumulated reserve to $431.0 million, according to the Controller's Office Six-Month Budget Status Report, FY2025-26.
View data as table
| Traditional property tax | $2,122.8M | revenue, FY2025-26 projected |
|---|---|---|
| Excess ERAF revenue | $362.3M | revenue, FY2025-26 projected |
| Set aside for AAB refund reserve | $105.2M | of total property tax revenue |
| Available for other General Fund spending | $2,379.9M | of total property tax revenue |
The reserve isn't hypothetical caution. Through January 31, 2026 — seven months into the fiscal year — the city had already refunded roughly $64 million from prior years' property tax collections. That's most of the way to the $79 million it refunded across the entirety of the previous fiscal year, with five months of FY2025-26 still to run. The 14,652 open appeals the AAB is still sitting on cover $281.6 billion in currently assessed value — property whose owners believe the number on their tax bill is wrong, and who are, under Revenue and Taxation Code §1604, entitled to have that belief become the assessed value automatically if the city runs out the two-year clock.
The same system, counted in people
The appeals don't resolve themselves. Real-property appraisers value the disputed properties, defend those values, and negotiate or litigate the cases that reach a hearing. San Francisco's Annual Salary Ordinance for Budget Years 2024-2025 and 2025-2026, passed by the Board of Supervisors, shows how many of those appraisers the city actually budgeted for.
View data as table
| FY 2024-25 | 68.28 FTE | Real Property Appraiser classes 4261/4265/4267 |
|---|---|---|
| FY 2025-26 | 69.00 FTE | Real Property Appraiser classes 4261/4265/4267 |
Across every division that carries a real-property appraiser line, the city budgeted 68.28 for FY2024-25 and 69.00 for FY2025-26 — a gain of 0.72 , all of it a single Principal Real Property Appraiser position moving from partially funded to fully funded. That 0.72 is not just the appraisal corps' growth — it is the entire net staffing increase for the whole 204-person Assessor-Recorder department this year. Every other division's budgeted headcount, from the Recorder's office to Standards and Mapping, is unchanged line for line between the two years in the ordinance. Sixty-nine appraisers, budgeted to carry a backlog of 14,652 open cases — roughly 212 open appeals for every appraiser on staff, before any of them touch this year's new filings.
The takeaway
- The two-year clock is the real deadline, not the fiscal year. California law converts an unheard appeal into an automatic win for the taxpayer after two years — the AAB's backlog isn't just an accounting problem, it's a countdown on $281.6 billion in disputed value.
- The city is already paying for it. $431.0 million is sitting in reserve for refunds, funded by holding back current property tax revenue that would otherwise be spendable — and the pace of refunds paid this fiscal year is already closing in on all of last year's, with a third of the year still left.
- Staffing didn't move with the caseload. Filed appeals roughly tripled by the Assessor-Recorder's own account; the Board of Supervisors' budget added three-quarters of one appraiser position to the entire department in response.
Figures describe San Francisco's General Fund and Assessor-Recorder department budget only; appeals data reflect open cases as of January 29, 2026, and change as the Assessment Appeals Board rules on them.
Sources
- San Francisco Controller's Office — Six-Month Budget Status Report, FY2025-26 (Feb. 12, 2026): property tax revenue by source, the AAB reserve deposit and cumulative reserve balance, open-appeals count and contested value, and refunds paid to date. media.api.sf.gov
- San Francisco Board of Supervisors — Annual Salary Ordinance (2-Year), Budget Years 2024-2025 and 2025-2026, Department ASR (Assessor/Recorder): budgeted by job class and division, used for the real-property appraiser staffing figures and the department-wide total. sfgov.legistar.com
- California Legislative Information — Revenue and Taxation Code §1604: the two-year statutory deadline and the deemed-value default rule for unheard assessment appeals. leginfo.legislature.ca.gov
- San Francisco Assessor-Recorder — Assessor-Recorder Joaquín Torres Presents 2024-2025 Assessment Roll (Aug. 6, 2024): the office's own account of a roughly three-fold rise in newly filed assessment appeals. sf.gov
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Every California property owner who thinks a county over-valued their land or building can file an appeal, and the county has two years to rule on it — after that, state law hands the owner their own requested value by default. San Francisco's downtown office towers lost value fast after 2020, and the appeals followed. The city's own Assessor-Recorder said in an August 2024 statement that newly filed appeals had risen roughly three-fold. By this January, the backlog had a price tag: $281.6 billion in assessed value sitting in cases nobody has ruled on yet.