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Effective / Relevant Date:Jan 1, 2027
Nearly every point of confusion about HOTMA compliance traces back to a single structural fact: HUD is implementing it through three different program offices, each issuing its own guidance on its own schedule. An owner or agency operating across program types can be subject to more than one notice in the same portfolio.
As of December 30, 2025, all three tracks share a compliance date. They do not share a route to it.
Track 1 — Public and Indian Housing (PIH)
Programs: Public Housing, Housing Choice Voucher, Project-Based Voucher, Moderate Rehabilitation, Moderate Rehabilitation Single Room Occupancy
Governing notice: PIH 2026-15, issued May 14, 2026 (partially supersedes PIH 2024-38)
Where it stands: A first set of provisions — new income exclusions, certain definitions, and de minimis error policies — has been mandatory since July 1, 2025. HUD begins enforcing the remaining Sections 102 and 104 provisions on January 1, 2027 for non-MTW and non-FRS agencies. The notice also sets out alternative HUD-50058 reporting instructions.
Track 2 — Multifamily Housing (Office of Housing)
Programs: Those listed in Section 4 of Notice H 2023-10, HUD's base HOTMA implementation notice for multifamily owners
Governing notice: H 2025-07, issued December 17, 2025 (supersedes H 2024-09 and H 2025-03)
Where it stands: Full compliance with the HOTMA final rule and HUD's updated income and asset documentation requirements for income certifications is due January 1, 2027. This date replaced a prior date of January 1, 2025. There is no interim phase — the obligation arrives whole.
Track 3 — Community Planning and Development (CPD)
Programs: HOME, HOME-ARP, Housing Trust Fund, HOPWA, CDBG, Emergency Solutions Grants, Continuum of Care, and CPD programs funded competitively — covering 24 CFR parts 5, 92, 93, 570, 574, 576 and 578
Governing action: Federal Register Doc. 2025-23989, published December 30, 2025 (90 FR 61062), superseding Doc. 2024-31401
Where it stands: Compliance due January 1, 2027, extended from a previous date of January 1, 2026. Income-determination safe harbors remain available ahead of the deadline — ESG, CoC and HOPWA grantees under 24 CFR 5.609(c)(3), which permits reliance on income determinations made under other federal programs, and HOME and Housing Trust Fund grantees under provisions allowing acceptance of determinations from PHAs, rental subsidy providers, or public housing programs. Grantees using a safe harbor must update program guidelines and establish policies first.
The underlying rule
All three tracks implement the same instrument. HOTMA was signed into law on July 29, 2016. HUD published the final rule implementing Sections 102, 103 and 104 on February 14, 2023, at 88 FR 9600, effective January 1, 2024 — with certain amendments effective March 16, 2023. What has moved repeatedly since is not the rule. It is the date each office requires compliance with it.
What to do with this
Identify every program in your portfolio and map each one to its track. A shared date does not mean a shared obligation: a PHA has interim requirements already in force since July 2025 that a multifamily owner never had, and a CPD grantee has safe harbors available that neither of the others can use. An organization spanning all three is managing one deadline and three sets of guidance.
1. Inventory each assisted program and identify its governing PIH, Multifamily Housing or CPD guidance.
2. Confirm which provisions are already required, which remaining requirements apply to January 2027 transactions, and whether an exception or optional early implementation applies.
3. Align written policies, staff training, verification procedures and software with the appropriate notice. Check the latest HUD instructions before relying on a deadline or reporting workaround.
HOTMA implementation depends on the assisted program, not simply the property or organization. The cited PIH, Multifamily Housing and CPD guidance points to January 1, 2027 for the covered requirements, but prior obligations, exceptions and reporting routes differ. A shared date does not replace a program specific compliance plan.
PHAs administering covered PIH programs, owners and agents in the multifamily programs covered by Notice H 2023-10, and grantees in the CPD programs addressed by the applicable extension. Mixed portfolios may need more than one set of instructions. MTW agencies and agencies exclusively using FRS must check their separate treatment under PIH 2026-15.
HUD is implementing HOTMA through three program offices under three separate notices. As of December 2025 all three land on January 1, 2027 — but they get there by different routes, and which notice governs you depends on your program, not your property.
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