On November 26, 2025, the U.S. Census Bureau announced that the release of the 2020-2024 American Community Survey (ACS) data will be delayed from December 11, 2025, to January 29, 2026. The postponement, resulting from the recent federal government shutdown, will quickly affect the affordable housing industry — and the first place many owners, agents, and investors will notice it is in the publication of HUD’s annual income limits.

HUD relies heavily on ACS data as the foundation for calculating income limits across multiple programs, including Section 8, HOME, CDBG, LIHTC, and the MTSP limits used in tax credit properties. Under normal circumstances, HUD releases updated limits on April 1 each year, a date the agency fervently defends as if it were a national holiday. But without ACS data, HUD’s options are limited. No ACS figures mean no base median income calculations, no trend factors, and no finalized limits.

With ACS data arriving nearly six weeks late, HUD loses a significant portion of its usual modeling and quality-control window. Historically, HUD requires 60 to 75 days after receiving ACS data to prepare income limits for publication. That timeline alone makes an April 1, 2026, release virtually impossible. The closest historical parallel—the 2018-2019 shutdown—resulted in a similar delay, and HUD responded the same way: by pushing income limits several weeks past the regular schedule.

Housing professionals should plan for the 2026 limits to be published sometime between late April and mid-May. While HUD has not yet issued an official notice, all evidence points to a delay.

Operationally, the impact varies by program. LIHTC and tax-exempt bond properties will continue using existing limits until new ones are announced, with no mid-year recalculation necessary. HUD-subsidized programs will operate similarly — households are not reprocessed, and rents stay linked to the previous limits until the new figures are published.

For now, the best approach is straightforward: expect a delay, update internal schedules, communicate early with owners and investors, and avoid scheduling rent-setting or compliance deadlines that rely on an April 1 release.

When HUD finally posts the 2026 limits, they’ll still come with all their usual fanfare — just fashionably late.