On May 29, 2025, the U.S. Department of Housing and Urban Development (HUD) officially extended the HOTMA implementation deadline for Sections 102 and 104 of the Housing Opportunity Through Modernization Act of 2016 (HOTMA). The new mandatory compliance date is now January 1, 2026, providing multifamily property owners and managers with an additional six months to meet the requirements outlined in the final rule.
Background on HOTMA Compliance
HOTMA, enacted in 2016, introduced significant reforms to income and asset verification for HUD-assisted housing. Sections 102 and 104 specifically address tenant income calculations, asset limits, and streamlined recertification policies.
Originally, HUD required full compliance for income certifications effective on or after January 1, 2025, as stated in Notice H 2023–10. This deadline was later extended to July 1, 2025 via Notice H 2024–09. However, with the publication of Notice H 2025–03, HUD now provides an extended timeline to ensure smoother implementation across multifamily housing programs.
This deadline extension applies to owners and operators participating in HUD Multifamily Housing programs covered under Notice H 2023–10. These include property owners, contract administrators, regional center directors, asset management divisions, and field counsel.
The additional time allows these stakeholders to:
- Finalize and implement HOTMA-compliant policies and procedures
- Complete system updates for income and asset documentation
- Train staff and educate residents on the new requirements
Key Takeaway: New Compliance Deadline – January 1, 2026
HUD’s decision to extend the HOTMA compliance date to January 1, 2026, also offers much-needed flexibility for owners and agents working to align with complex regulatory changes. It also demonstrates HUD’s ongoing commitment to supporting housing providers through operational transitions.
For questions or clarification about the updated notice, stakeholders are encouraged to contact HUD directly.
Need help preparing for HOTMA compliance? Stay tuned to our blog for future updates, guidance, and practical tools to support the implementation.
