HUD has issued Notice H 2025–07, extending the compliance deadline for certain provisions of the Housing Opportunity Through Modernization Act of 2016 (HOTMA). Under the new guidance, implementation of HOTMA Sections 102 and 104 for HUD Multifamily Housing is now required beginning January 1, 2027.
What Changed
Previously, multifamily owners were required to be fully compliant with HOTMA income and asset provisions by January 1, 2026. Notice H 2025–07 formally revises that date to January 1, 2027, amending Section 6.2 of HUD’s HOTMA implementation guidance (Notice H 2023–10).
This revised date applies to owners participating in the HUD Multifamily Housing programs identified in the applicability section of Notice H 2023–10.
What This Means for Multifamily Owners
For income certifications with an effective date on or after January 1, 2027, owners must fully comply with:
- HOTMA Sections 102 and 104
- HUD’s updated income and asset documentation requirements
Until that time, owners should continue to follow current HUD program rules and existing guidance, unless otherwise directed.
This notice changes only the compliance date. All underlying HOTMA requirements remain in effect and will apply once the revised deadline is reached.
What Owners Should Do Now
The extended timeline provides additional time for owners to prepare for implementation. During this period, owners may wish to:
- Continue staff training on HOTMA requirements
- Review internal policies and procedures for alignment with HOTMA rules
- Monitor NCHM and HUD communications for additional guidance or clarification
- Confirm and monitor compliance dates for any other programs you may work with that are not covered in this notice
Using this time to prepare can help ensure a smoother transition when the compliance date arrives.
Bottom Line
HUD has extended the HOTMA compliance deadline for Multifamily Housing to January 1, 2027. While full compliance is not required until that date, owners should remain engaged and continue preparing to meet HOTMA requirements when they take effect.