NSPIRE Wire is independent and not affiliated with HUD.
Effective Date:Jan 1, 2027
HUD plans to give owners in its Multifamily Housing programs another year to comply with HOTMA’s income and asset changes, according to a September 16 report from the Public Housing Authorities Directors Association.
PHADA reported that HUD Office of Housing staff announced a planned January 1, 2028 compliance date during the association’s 2026 Legislative Forum. The extension would include Project-Based Rental Assistance properties.
The formal announcement was still moving through HUD’s approval process and was expected in the coming weeks, PHADA said. Read PHADA’s report.
For owners and agencies, the immediate issue is identifying which schedule applies. A planned Multifamily extension does not move public housing and voucher programs to 2028.
Formal Multifamily Guidance Is Still Pending
As of NSPIRE Wire’s September 18 review, HUD’s Multifamily HOTMA resource page continued to list January 1, 2027 as the full-compliance deadline. HUD’s published Housing Notices index did not list the announced 2028 extension.
The existing deadline comes from Notice H 2025-07, issued December 17, 2025. That notice extended Multifamily compliance to January 1, 2027 and remains in effect until amended, superseded or rescinded. Read Notice H 2025-07.
Owners can prepare for the announced extension, but should retain the published requirement in their compliance records until HUD issues the replacement instructions.
The forthcoming document will be needed to confirm the extension’s precise coverage, transition provisions and treatment of owners that have already implemented HOTMA.
PBRA and PBV Follow Different Schedules
Project-Based Rental Assistance, or PBRA, falls within HUD’s Multifamily Housing programs.
Project-Based Vouchers, or PBV, operate through the Housing Choice Voucher program under Public and Indian Housing.
Those similar names can create confusion when a deadline changes. PHADA specifically identified PBRA as part of the planned Multifamily extension and said the PIH schedule, including PBV, remains unchanged.
Organizations administering multiple assistance types should track implementation by program and contract, rather than assigning one HOTMA deadline to their entire portfolio.
Most PHAs Still Have a January 2027 Deadline
HUD Notice PIH 2026-15 establishes January 1, 2027 enforcement of full HOTMA Sections 102 and 104 compliance for most PHAs.
For agencies covered by that deadline, HUD-50058 transactions effective January 1, 2027 or later must comply with HOTMA.
The notice contains two exceptions:
Agencies participating in the Moving to Work demonstration.
Agencies exclusively using HUD’s Family Reporting Software when the notice was published.
HUD assigns those groups separate timing tied to system changes and further guidance. The notice also preserves earlier requirements, including selected provisions that PHAs had to implement by July 1, 2025.
Agencies that begin annual reexaminations 120 days before their effective date need to begin HOTMA collection and verification procedures in September 2026 for January 2027 transactions. The notice supplies alternative reporting instructions for agencies unable to transition to the updated HUD-50058 in time. Read Notice PIH 2026-15.
What Sections 102 and 104 Cover
HOTMA, the Housing Opportunity Through Modernization Act of 2016, changes how housing providers determine income, review household circumstances and evaluate assets.
Section 102 addresses income reviews and related income and asset rules. Section 104 establishes asset limitations for covered programs.
Their applicability is not identical. HUD’s implementation guidance applies Section 102 to several Multifamily programs, including PBRA, Section 202/8 and specified Section 202 and Section 811 assistance programs. Within Multifamily, Section 104 applies to PBRA and Section 202/8, but not every program covered by Section 102.
The announcement concerns implementation timing. Owners should continue using HUD’s program-specific applicability instructions when reviewing eligibility policies. See HUD’s implementation guidance, Revision 3.
Early Adoption Requires Coordinated Procedures
HUD’s current Multifamily guidance allows owners to adopt HOTMA before the mandatory deadline.
Its published instructions describe calculating income and rent manually and using the rent override function in TRACS version 202D when necessary before TRACS 203A is available. Owners must also document their implementation in tenant files. See HUD’s Multifamily HOTMA resources.
However, adopting individual provisions requires care. HUD warns that many HOTMA provisions are interconnected. Implementing some without others may be impractical or affect tenant rents.
HUD’s rent override instructions require records identifying the provisions implemented, how income, assets and deductions were determined, and applicable comparisons between pre-HOTMA and HOTMA rent calculations. HUD also encourages owners to notify their contract administrators before using the override process.
These instructions should be read alongside subsequent deadline notices because the older document contains dates that have since changed. Read HUD’s rent override instructions.
Policy Preparation Should Continue
An anticipated extension gives management teams an opportunity to review their implementation work.
Recommended preparations include reconciling tenant selection plans with operating procedures, checking EIV policies, testing software calculations and identifying where staff need additional training.
HUD’s published Multifamily page separately identifies the earlier requirement to update tenant selection plans and EIV policies by May 31, 2024. Owners should not assume an extension of full implementation also postpones previously completed policy deadlines.
Owners that already use HOTMA should review the forthcoming notice before considering changes to their established procedures.
Use the Correct Annual Values
HUD publishes annual inflation adjustments and a passbook rate for programs implementing the applicable HOTMA provisions.
The HUD User resource currently includes the calendar year 2027 amounts. Its instructions also explain that administrators not yet complying with Sections 102 and 104 do not use that table.
A deadline announcement should therefore prompt a review of both the property’s implementation status and the values its software applies. Access HUD’s annual adjustments and passbook rates.
What to Watch for Next
The next controlling development will be HUD’s written Multifamily extension notice.
Owners should check whether it changes only the compliance date or also addresses early implementation, existing adopters, reporting procedures and certification effective dates.
Until that document is published, the clearest approach is to record January 2028 as an announced Multifamily extension pending formal guidance, while continuing program-specific preparation under the published notices.
1. Track PBRA and PBV separately and identify the governing notice for each program. Keep the published requirement in compliance records until HUD issues controlling replacement guidance.
2. Continue preparing policies, documentation, training and software for the applicable program. A proposed extension should not be treated as postponing earlier policy obligations.
3. Before changing implementation dates or reversing early adoption, check the current HUD Multifamily resource page and written notices for coverage, certification effective dates and transition instructions.
A reported plan to extend Multifamily HOTMA compliance to January 2028 is not the same as published replacement instructions. Owners need to distinguish that announcement from the operative notice. It does not move the PIH schedule, so a mixed portfolio cannot adopt one 2028 deadline for every assistance type.
HUD Multifamily owners and agents, including PBRA providers, and PHA teams administering public housing, HCV and PBV. Contract administrators, certification staff and software vendors need program specific instructions. MTW agencies and agencies exclusively using FRS must check their separate PIH treatment rather than assume the general date applies.
PHADA reports that HUD staff announced plans to extend Multifamily HOTMA compliance to January 1, 2028. Formal HUD guidance remains pending. Most PHAs retain a January 1, 2027 deadline, with separate timing for Moving to Work agencies and qualifying Family Reporting Software users.
Editorial Desk
The NSPIRE Wire Editorial Desk publishes source-verified reporting and analysis covering HUD policy, NSPIRE inspections, affordable housing finance, development, transactions, and the people shaping the industry.
Know something we should know? Have documents, corrections, or related developments on this topic? Send an editorial tip to our reporters.
