HUD’s 2027 deadline shift
HUD issued a HOTMA compliance extension for Multifamily owners.
This change resets planning for 2026 and early 2027. It can also reduce resident disruption during transition.
On December 17, 2025, HUD released Notice H 2025–07. The Notice extends the full compliance date for HOTMA Sections 102 and 104. Owners must now be fully compliant by January 1, 2027. This Notice supersedes prior deadline notices and cross-references Notice H 2023–10 for implementation guidance.
Deadline changes can feel like “good news.” However, they are better viewed as “risk management.” Your job is to use this extra time to improve accuracy, thereby protecting households and subsidy dollars.
The HOTMA Timeline in HUD Multifamily Housing
Multifamily, HUD’s main playbook is Notice H 2023–10. That guidance set a full compliance target of January 1, 2025. HUD then extended the date to July 1, 2025, and later extended the date to January 1, 2026.
Today, HUD is setting the HOTMA compliance deadline for January 1, 2027. This extension applies to Owners in programs listed in Notice H 2023–10. If your property is in that set, align your workplan today.
A later deadline still creates a fixed compliance event. HOTMA changes touch everyday certification work and reshape income determinations and net family asset treatment. They also affect deductions, hardship relief, and reexamination rules.
For owners interested in early adoption, you can make it work if you maintain consistent files. The process fails when staff apply rules differently across cases.
Also, if you pilot, pilot small and use a defined unit group and a fixed period. This allows you to measure outcomes and resident questions.
Here are five readiness checks you can run now. Each one reduces both errors and resident frustration.
- Confirm that your verification checklist aligns with HOTMA rules.
- Identify forms and letters that reference older calculations.
- Validate software outputs against manual test cases.
- Build a file note template for every “judgment” decision.
- Set a quality-control cadence and stick to it.
The HOTMA compliance extension gives you a full year to get ready. Do not delay preparation.
Treat 2026 as your build year.
