Implementation of HOTMA Sections 102 and 104 has been delayed to January 1, 2028, for HUD Multifamily Housing (MFH) Programs.
This comes several weeks after the Public Housing Authorities Directors Association’s (PHADA) Legislative Conference in September of 2026, where HUD officials announced they anticipated such a delay.
The official announcement was issued on November 2, 2026, as HUD Notice 2026-07.
The new compliance date does not impact HUD’s Public and Indian Housing Programs, which deliver Housing Choice Vouchers (HCVs) and manage PHA-owned public housing units. PHAs are still required to implement HOTMA by January 1, 2027.
Owners and Agents of projects that fall under HUD’s MFH office – such as project-based Section 8, Section 202, and Section 811 – will not be required to update their programs to be in compliance with new subjects, such as asset limitations, updated income exclusions, or new forms. These projects should continue to follow “pre-HOTMA” guidance through the upcoming year.
For other housing programs, such as the Low-Income Housing Tax Credit program, please refer to your program administrator’s implementation dates.