HOTMA Timelines Keep Moving. Your Preparation Shouldn't Stop.
If you manage HUD-assisted multifamily housing, you have watched the HOTMA compliance date move more than once.
HUD first set January 1, 2025 for full compliance with HOTMA's income and asset rules. That moved to July 1, 2025, then to January 1, 2026, and then to January 1, 2027 through Notice H 2025-07.
Now there is more news. At PHADA's 2026 Legislative Forum, HUD Office of Housing staff said the Department plans to delay the multifamily compliance date again, to January 1, 2028. Staff said a formal announcement is still going through approval and should be published in the coming weeks. Until it is, this is an announced plan, not a final notice, so keep an eye on HUD's website for the official word.
Know which timeline applies to you
Not every program runs on the same clock. The announced delay covers HUD Multifamily programs, including Project-Based Rental Assistance. Public housing and Housing Choice Vouchers remain on a January 1, 2027 date. USDA Rural Development set its own date and began its transition in 2025. If your portfolio mixes program types, confirm the date for each one.
Why the dates keep shifting
The reasons are mostly practical. Updated forms, model leases, and TRACS changes have not been ready, and it is hard to require compliance when the systems cannot yet process HOTMA-compliant certifications.
A later date is not a reason to wait
The rules themselves have not gone away. Income calculations, asset limits, and recertification steps will change. The owners who feel the least stress when the date arrives will be the ones who used the extra time well.
Sort your properties by program type and confirm each compliance date.
Review your Tenant Selection Plans for HOTMA updates.
Ask your software vendor what they will support and when.
Train your staff before the rules go live, not after.
Get your HOTMA questions answered on October 14
With dates shifting, the best move is to hear from someone who follows this closely. Mid-Atlantic CAH is hosting a webinar on October 14 on HOTMA compliance, led by expert Gary Kirkman. Bring your questions about what this means for your properties and how to plan.