The Department of Housing and Urban Development (HUD) on May 29, 2025 officially delayed the Multifamily Housing compliance date for the Housing Opportunity Through Modernization Act (HOTMA) until January 1, 2026.

HUD’s Notice H-2025-03, which is only seven sentences long, officially delays the HOTMA compliance date by six months; the agency had previously extended the deadline to July 1, 2025, but HUD has not finalized the systems, forms, or materials needed to move forward with HOTMA implementation by then.

According to the new Notice, HUD-assisted Multifamily Housing owners are required to be in full compliance with the HOTMA final rule and HUD’s updated income and asset documentation requirements for income certifications having an effective date on or after January 1, 2026.

HOTMA was enacted by Congress in 2016 as a bipartisan streamlining and modernizing measure for HUD-assisted housing programs. The new rules change key elements of federal rental assistance, including how rent is calculated for assisted households and who is considered eligible for housing assistance. HOTMA also adjusts the recertification process that properties conduct.

In response to advocacy by LeadingAge to bring clarity to the implementation and compliance status, HUD recently told LeadingAge that housing providers participating in HUD’s Multifamily Housing programs should delay any HOTMA implementation until the agency’s Notice was published. The official document is here.

LeadingAge will work with our members to prepare for the January 1, 2026, deadline. Stay tuned for forthcoming trainings, and review our checklist for mission-driven approaches to discretionary policy changes under HOTMA, including an approach to a new asset limit that protects in-place residents.