News | HUD Extends Multifamily HOTMA Compliance Deadline to 2028
Nov 02, 2026
HUD has given Multifamily Housing owners another year to complete implementation of HOTMA.
On November 2, 2026, HUD issued Notice H 2026-07, extending the mandatory full-compliance date for Sections 102 and 104 of the Housing Opportunity Through Modernization Act of 2016 (HOTMA) to January 1, 2028. The notice supersedes Notice H 2025-07, which established a January 1, 2027 deadline.
What changed?
For HUD Multifamily Housing owners covered by Notice H 2023-10, the mandatory date for full compliance with the HOTMA final rule and HUD's updated income and asset documentation requirements for income certifications is now January 1, 2028.
The affected Multifamily programs include Section 8 Project-Based Rental Assistance (PBRA), Section 202/8, Section 202/162 PAC, Section 202/811 PRAC, certain Section 236 projects, Section 811 PRA, and SPRAC, as specified in Section 4 of Notice H 2023-10.
What did not change?
This is a compliance-date extension, not a change to the effective date of the HOTMA final rule. The final rule implementing Sections 102 and 104 became effective January 1, 2024.
The new notice also does not rescind the separate requirement for Multifamily owners to update their Tenant Selection Plans and EIV policies and procedures to reflect HOTMA rules and discretionary policies. HUD previously extended that policy-update deadline to May 31, 2024, in Notice H 2024-04.
HOTMA implementation differs across housing programs
The new notice applies to HUD Multifamily Housing. Other affordable housing programs have different implementation requirements and schedules.
Low-Income Housing Tax Credit (LIHTC). Many state housing finance agencies have already implemented HOTMA income and asset calculation requirements for LIHTC properties. Dates and specific agency requirements vary, and implementation should be checked with the applicable allocating agency. The new HUD Multifamily extension does not automatically postpone those state requirements.
Public Housing and Housing Choice Vouchers. Under Notice PIH 2026-15, HUD will enforce full compliance beginning January 1, 2027, for most public housing agencies. Different timing applies to specified Moving to Work agencies and agencies exclusively using HUD's Family Reporting Software. The notice also preserves the earlier July 1, 2025 compliance date for certain provisions identified in PIH 2024-38.
HOME, National Housing Trust Fund, and other HUD Community Planning and Development programs. HUD's Office of Community Planning and Development (CPD) extended the compliance date to January 1, 2027, through a Federal Register rule published December 30, 2025. Comprehensive program-specific implementation instructions remain limited, leaving grantees to work through program requirements and agency direction. Many HOME participating jurisdictions have already implemented HOTMA-based procedures, including some that also serve as LIHTC allocating agencies. The newly announced Multifamily extension does not itself change the CPD date.
USDA Rural Development. Rural Development implemented its applicable HOTMA requirements effective July 1, 2025. RD Multifamily tenant certifications effective on or after that date must follow the applicable provisions, subject to RD's own program rules and exclusions. RD did not adopt every HOTMA provision implemented by HUD.
The practical takeaway
HUD Multifamily owners now have another year before mandatory full HOTMA compliance: January 1, 2028 instead of January 1, 2027.
But that additional time is not universal. LIHTC agencies have already implemented many HOTMA requirements, RD implemented its applicable changes in July 2025, and HUD's PIH and CPD programs operate under different deadlines.
For properties combining HUD Multifamily assistance with LIHTC, HOME, NHTF, or RD financing, owners and agents should evaluate each program's applicable requirements rather than assuming the latest HUD extension governs the entire property.
Primary sources
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