State-by-state backbilling limits — my working list

I've been compiling a list of backbilling limits by state based on my own experience and research. Sharing what I have so far — please add corrections or states I'm missing. This is for utility overcharge refunds from the customer's perspective, not underbilling.

California: 3 years (CPUC Rule)
Georgia: 2 years (PSC Rule 515-3-3-.03)
Illinois: 2 years (ICC regulations)
New York: 3 years (PSC opinion)
Ohio: 4 years (contract statute, not PUC rule)
Pennsylvania: 3 years (PUC policy)
Texas: 4 years (contract statute)
Virginia: up to 5 years with discovery rule
Florida: 4 years (statute of limitations on contracts)
North Carolina: 2 years (NCUC general practice)

Anyone have additions?

Great resource. A few additions from my experience:

South Carolina: 3 years (PSC policy)
Tennessee: 6 years (contract statute — TVA distributors vary)
Alabama: 6 years (contract statute, but Alabama Power typically caps at 3)
Mississippi: 3 years (Entergy Mississippi policy)
Louisiana: 3 years (LPSC regulation)

The Tennessee one surprises people. The contract statute of limitations is 6 years and since TVA distributors don't have a specific backbilling rule, I've gotten 5-year refunds from Nashville Electric Service and EPB in Chattanooga.

Adding Midwest states:

Indiana: 3 years (IURC informal practice)
Michigan: 6 years (contract statute — DTE usually caps at 3)
Wisconsin: 6 years (contract statute — WE Energies varies)
Minnesota: 6 years (contract statute — Xcel typically does 3)

Notice the pattern — the contract statute in many states is longer than what the utility will voluntarily give you. The trick is knowing when to push beyond the utility's policy and cite the actual law.

This list is gold. Pinning this in my office. One critical note — these limits can differ depending on the TYPE of error. A wrong rate class might have a different recovery window than a wrong meter multiplier. Metering equipment errors often have longer recovery periods because they're considered utility-caused equipment failures rather than billing adjustments. Always check if there's a separate rule for metering errors versus rate application errors.

Adding a few more:

New Jersey: 3 years (BPU practice — PSE&G and JCP&L usually honor this)
Connecticut: 3 years (PURA policy)
Massachusetts: 6 years (contract statute — Eversource usually does 2-3)
Maryland: 3 years (PSC regulation)

And I'd note that in deregulated states like Texas, Pennsylvania, and parts of New York, you may need to pursue the refund from the REP, the utility, or both depending on where the error occurred.

This is one of the most valuable threads we've had on this forum. I'd encourage everyone to treat these as starting points rather than hard limits. The actual recovery period in any specific case depends on the utility's tariff, the state PUC's rules, the applicable civil statute of limitations, and your ability to negotiate. I've seen auditors accept a 2-year refund in a state where they could have gotten 4 years simply because they didn't push back. Know your state's laws, document the discovery timeline, and don't be afraid to escalate to the PUC. That said, always be honest about the timeline — never misrepresent when an error was discovered.