Affordable housing professionals working with HUD Multifamily Housing programs have been given additional time to prepare for HOTMA implementation. At PHADA’s 2026 Legislative Forum, HUD Office of Housing staff announced that the Department plans to delay the Multifamily Housing HOTMA compliance date—including Project-Based Rental Assistance (PBRA)—from January 1, 2027, to January 1, 2028.
HUD staff indicated that a formal announcement is moving through the Department’s approval process and is expected to be published in the coming weeks. Until that notice is issued, the 2028 date should be considered an announced, but not yet formally published, change.
Understanding HOTMA and Why the Compliance Date Matters
HOTMA was enacted in 2016 and made significant changes to federal housing programs, including the way HUD-assisted households’ income and assets are calculated and reviewed. Among its most consequential provisions are Section 102, which addresses income reviews and changes to income and asset definitions, and Section 104, which establishes asset limitations for certain HUD-assisted housing programs.
HUD finalized regulations implementing Sections 102, 103, and 104 in 2023, with the final rule becoming effective January 1, 2024. For Multifamily Housing, however, implementation has involved multiple extensions as HUD and the housing industry have worked to update policies, procedures, software, reporting systems, and other infrastructure necessary for full compliance.
The compliance date has already moved several times. HUD initially established an earlier implementation schedule, later moving the Multifamily deadline to July 1, 2025. Notice H-2025-03 subsequently extended the date to January 1, 2026, and Notice H-2025-07 moved it again to January 1, 2027.
The newly announced 2028 extension would therefore provide Multifamily owners with an additional year beyond the currently published deadline.
What the Delay Means
HOTMA made significant changes to HUD’s rules governing income, assets, reexaminations, and other aspects of affordable housing administration. The Multifamily implementation process has already experienced several delays as HUD and the industry work through policy, technology, software, and operational requirements.
The additional year gives Multifamily owners and management agents more time to review policies, update procedures, train staff, coordinate with software providers, and prepare for changes to income and asset calculations, documentation, and tenant certifications.
However, organizations should not assume that the delay applies to every HUD program.
Multifamily and PIH Have Different Deadlines
According to PHADA, the planned January 1, 2028 deadline applies to HUD Multifamily Housing programs, including PBRA. The current January 1, 2027 compliance date remains in place for Public and Indian Housing (PIH) programs, including Public Housing and Housing Choice Vouchers (HCVs), including Project-Based Vouchers.
This distinction is particularly important for organizations that operate across multiple HUD programs. Owners, PHAs, and management agents should identify which programs they administer and ensure that their preparation timeline reflects the applicable requirements.
How Housing Professionals Can Prepare
Even with the additional time, HOTMA preparation should continue. Multifamily organizations can use this period to:
- Review and update policies and procedures.
- Evaluate income, asset, and reexamination processes.
- Coordinate with software and technology providers.
- Train property, leasing, and compliance staff.
- Review documentation and resident communication procedures.
- Monitor HUD for additional guidance and the formal compliance notice.
The latest announcement provides Multifamily housing providers with additional time, but HOTMA remains a significant operational change. The best use of the extra year is to prepare now rather than wait for the new deadline.
This article reflects information available as of September 30, 2026. The January 1, 2028 Multifamily compliance date was announced by HUD staff but had not yet been formalized through a published HUD notice at the time of publication.
