2026 is off to a busy start in the affordable housing industry. In case you missed it, HUD officially announced a HOTMA Deadline shift in HUD Notice 2025-07. Now, professionals have more time to prepare for the implementation of HOTMA, which has been pushed to January 1, 2027.
In this week’s Tuesday Tip, we review what owners and agents should do right now to maximize this extra time to prepare for HOTMA.
What The HOTMA Deadline Shift Doesn’t Mean
This delay doesn’t mean HOTMA is on pause. It also doesn’t mean compliance can wait.
Some updates were already required, especially when it comes to your Tenant Selection Plan and EIV policies and procedures. Those updates were due back in May 2024, and HUD has started issuing findings when plans are missing, outdated, or incorrect.
If those documents haven’t been reviewed recently, now is the time.
Use This Extra Year the Smart Way
Think of the HOTMA deadline shift as bonus time—not free time.
This is a great window to train staff, answer questions, and build comfort with the changes ahead. Even light training now can prevent big mistakes later.
It’s also a good time to start educating residents. HOTMA is complicated, but there are tools that can help explain what’s coming in plain language.
About Those Discretionary Policies…
The HOTMA Deadline Shift doesn’t stop owners from implementing certain discretionary policies early. Some of these touch income calculations, asset limits, exclusions, inflation adjustments, and verification flexibility.
That said, many compliance professionals recommend waiting until TRACS 203A is fully enforced before making changes.
If you do decide to move ahead early, documentation is everything. Your Tenant Selection Plan should clearly spell out what you’re implementing and why. And your files should always tell the full story behind the numbers.
HOTMA Deadline Shift Offers Time for Policy Checkups
This extra year is perfect for a compliance tune-up. Again, use this extra time to review:
- Tenant Selection Plans
- Occupancy standards
- LEP policies
- Marketing plans (remember the five-year review rule)
- Reasonable accommodation policies
- Required postings
- Staff training records
One reminder that hasn’t changed: your obligation to assist residents with limited English proficiency is still very much in place.
As our Tuesday Tip outlines, the HOTMA deadline shift gives you more time, not a free pass. Policies still need attention. Staff still need training. Documentation still matters. HOTMA may be further out, but preparation shouldn’t stop.
