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Event / Action Date:Jan 1, 2027
HUD's Office of Public and Indian Housing issued Notice PIH 2026-15 on May 14, 2026, establishing that the department will enforce compliance with Sections 102 and 104 of HOTMA beginning January 1, 2027 for most public housing agencies.
The notice — formally "Public Housing Agency Compliance Deadline for Sections 102 and 104 of the Housing Opportunity Through Modernization Act (HOTMA) and Alternative HUD-50058 Reporting Instructions" — applies to agencies administering Public Housing, Housing Choice Voucher, Project-Based Voucher, Moderate Rehabilitation, and Moderate Rehabilitation Single Room Occupancy programs. The January 1, 2027 enforcement date is stated for non-MTW and non-FRS agencies.
It partially supersedes Notice PIH 2024-38, which had governed the enforcement timeline previously.
The notice does not reset everything to January. Provisions HUD had already made mandatory — new income exclusions, certain definitions, and policies addressing de minimis errors — took effect for public housing and HCV programs on July 1, 2025, and remain in force. What the 2027 date governs is HUD enforcement of the balance of Sections 102 and 104.
Alongside the compliance date, the notice sets out alternative HUD-50058 reporting instructions.
The notice states that it remains in effect until amended, superseded, or rescinded.
1. Replace PIH 2024-38 with PIH 2026-15 in your internal reference materials and staff training. 2. Confirm the July 1, 2025 provisions — income exclusions, definitions, de minimis error policies — are documented and in practice now. 3. Review the alternative HUD-50058 reporting instructions in the notice and confirm your software vendor's support timeline. 4. If you are an MTW or FRS agency, read the notice for your treatment rather than assuming the January 1, 2027 date applies.
PIH 2026-15 is the operative document for public housing agencies on HOTMA — it is the notice that sets the enforcement date and the one an agency should be working from. Agencies still referring to PIH 2024-38 are working from guidance that has been partly replaced. The notice also confirms that the July 1, 2025 obligations did not move: those provisions are in force now, regardless of what happens in January.
Public housing agencies administering Public Housing, Housing Choice Voucher, Project-Based Voucher, Moderate Rehabilitation and Moderate Rehabilitation Single Room Occupancy programs, specifically non-MTW and non-FRS agencies. Also relevant to PHA compliance and occupancy staff, and to software vendors supporting HUD-50058 submissions.
The May notice partially supersedes PIH 2024-38 and pairs the compliance date with alternative HUD-50058 reporting instructions.
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