HUD Holds Firm — For Now — on January 1, 2026 HOTMA Implementation Deadline
As of mid-October 2025, there is no indication that HUD will postpone the January 1, 2026, compliance deadline for the Housing Opportunity Through Modernization Act (HOTMA). Despite ongoing delays in finalizing forms, leases, and system updates—and the additional disruption caused by the federal government shutdown and HUD staff reductions—HUD has not issued any new notices delaying implementation.
Background
HUD previously extended key compliance dates for HOTMA under Notice H-2025-03, published on May 29, 2025. That notice delayed the effective date of Sections 102 and 104 (income, asset, and eligibility rules) for Multifamily Housing programs from July 1, 2025, to January 1, 2026. The same compliance date applies to CPD programs (including HOME, CDBG, and HOPWA), showing HUD’s recognition that critical infrastructure—especially TRACS 203A and the new model lease—was not yet prepared.
Current Status
Since that extension, HUD has not issued any further guidance indicating another delay. Federal Register notices, HUD’s website, and major industry groups (NAHMA, PHADA, NCHM, etc.) all confirm that January 1, 2026, remains the official deadline for HOTMA implementation. Although HUD has not yet released the final HOTMA-compliant forms and lease templates, there is no public statement linking these delays to another official postponement.
Impact of the Government Shutdown
The ongoing federal shutdown has slowed operations across HUD. Many staff members are furloughed, and progress on TRACS 203A and the updated lease package has been delayed. However, unless HUD issues a formal notice through the Office of Multifamily Housing Programs or the Federal Register, the statutory compliance date of January 1, 2026, remains unchanged.
Related Extension — HOME Program Standards
It’s worth noting that HUD issued an unrelated extension on October 22, 2025, delaying the implementation of the Green Building Standards and Tenant Protections for the HOME Investment Partnerships Program until April 30, 2026. That change reflects the same operational reality—HUD’s systems and supporting guidance are not yet ready—but it applies only to HOME program standards, not to the HOTMA rules themselves.
What to Expect
Given HUD’s history of incremental extensions and ongoing technical delays, a further delay in HOTMA requirements remains possible, especially if system readiness or documentation issues continue into early 2026.
Until a new notice is issued, owners, agents, and PHAs should keep preparing for compliance by the January 1, 2026, deadline.
Bottom Line
HUD has not postponed HOTMA implementation again, but the combination of missing forms, unfinished system updates, staff cutbacks, and a government shutdown means another delay remains a real possibility. For now, proceed as if January 1, 2026, is fixed—while keeping an eye on HUD’s next notice.