HOTMA 2027: Another Year of Breathing Room. Don't Waste It.
HOTMA 2027 is no longer the compliance deadline for HUD Multifamily properties.
On November 2, 2026, HUD issued Notice H 2026-07, extending mandatory compliance with HOTMA Sections 102 and 104 from January 1, 2027, to January 1, 2028, for Multifamily project-based rental assistance programs.
That's welcome breathing room for Section 8 PBRA, Section 202, and Section 811 owners. But the extension isn't a pause button, and it doesn't apply to everyone.
Public housing agencies and properties subject to applicable HOME and HTF requirements still face January 1, 2027—just weeks away.
For operators managing layered or mixed portfolios, two HOTMA compliance timelines are now running at once.
Not sure where your portfolio stands? Take our free HOTMA Readiness Assessment.HOTMA Compliance Assessment.
Where the dates stand now
| Program | HOTMA compliance date | Source |
|---|---|---|
| HUD Multifamily (Section 8 PBRA, 202, 811) | January 1, 2028 | Notice H 2026-07 |
| Public Housing, HCV, PBV | January 1, 2027 (MTW and FRS-only PHAs on separate dates) | Notice PIH 2026-15 |
| HOME, HTF and other CPD programs | January 1, 2027 | Federal Register, Dec. 30, 2025 |
| LIHTC | Set by each state agency | Your state agency's guidance |
| USDA Rural Development | Already applies HOTMA's income and asset changes | USDA RD |
The Multifamily date has now moved four times: January 1, 2025, then July 1, 2025, then January 1, 2026, then January 1, 2027, and now January 1, 2028. Every extension has had the same cause. HUD's systems and forms, especially TRACS 203A, haven't been ready.
What H 2026-07 actually changes for Multifamily owners
Less than you might hope. The notice changes the date, not the rules. According to HUD's announcement:
Full compliance is mandatory for certifications effective on or after January 1, 2028.
You can still comply early by calculating HOTMA incomes and rents and entering them through the TRACS 202D rent override function. If you do, annotate your tenant files to show which HOTMA change you applied.
MOR treatment is softer for now. Before January 1, 2028, Contract Administrators will issue observations with corrective actions for HOTMA-related tenant file errors, not findings.
Your current policies stay in force. Keep following your existing Tenant Selection Plan and EIV policies and procedures until you're fully compliant with HOTMA.
That third point is the one people will misread. Observations aren't free. They still come with corrective actions, and they tell your Contract Administrator exactly where to look in 2028.
TRACS 203A: still a draft
On September 2, 2026, HUD posted the draft TRACS 203A MAT Guide for comment, along with draft versions of the HUD-50059 and the HUD-52670 voucher. The comment period closed October 2.
The draft covers updated adjustment and tenant rent calculations, imputed income proration and non-citizen proration, and separates certifications processed under 202D rules from those under 203A and HOTMA rules. What's still missing:
A final MAT Guide
A 203A go-live date. Until then, no software vendor, site or Contract Administrator can transmit 203A certifications.
Approved HOTMA model leases, which are still under OMB review
Watch HUD's Multifamily TRACS page for the final release. When it comes, ask your TRACS software vendor how quickly they'll support it and how they'll handle corrections to 202D certifications.
The paperwork still has to match the practice
The date keeps moving. The documentation expectations don't.
Keep two Tenant Selection Plans. Keep your current, pre-HOTMA TSP in force, and keep a HOTMA-compliant version ready. Redline the pre-HOTMA version so reviewers can see the HOTMA changes at a glance. Contract Administrators review both during MORs until you're operating fully under HOTMA.
Review your EIV procedures. HUD revised Notice H 2023-10 in April 2026, including updated guidance on EIV master reports in Table J1 and a change to when interim reexaminations are required (Notice H 2026-05). If your written procedures predate those changes, review them now.
If you implemented HOTMA early, document it. This is the gap we see most often: properties that use parts of HOTMA in practice, like new asset rules or medical deduction changes, without written policy to back it up. If it's in your files but not your policies, it will be flagged. Your resident files should show which HOTMA rules were applied, from what date, and whether the rent override was used.
The Audit Readiness Checker is a quick way to spot where your files and policies don't line up.
Forms: moving, but not done
| Form | Status |
|---|---|
| HUD-50059 / 50059-A | Draft released with the 203A MAT Guide; comment period closed October 2, 2026 |
| HUD-52670 voucher | Draft released; comment period closed October 2, 2026 |
| HOTMA model leases | Under OMB review, not yet approved |
| HUD-9887 / 9887-A consent forms | Awaiting final approval |
| VAWA forms HUD-5380 through 5384 | Final and in use; expire January 31, 2028 |
VAWA is the one piece that's done. Give Forms 5380 and 5382 to new residents at move-in, and include them with rejection letters and adverse action notices where VAWA applies. If your copies don't show a January 31, 2028 expiration, you're using old versions.
When the HOTMA model leases are approved, every Multifamily household will need to sign one. HUD has said it won't review owner-created HOTMA lease addenda until OMB approves the model leases, so plan a changeover schedule now rather than sending notices to your whole rent roll at once.
The numbers, and who uses them when
HUD published the calendar year 2027 inflation-adjusted values in August 2026:
| Figure | 2027 amount |
|---|---|
| Passbook savings rate | 0.38% |
| Net family asset limit | $109,797 |
| Asset self-certification and imputed income threshold | $54,898 |
| Dependent deduction | $525 |
| Elderly or disabled family deduction | $575 |
Who uses these figures changed with H 2026-07:
PHAs and HOME and HTF properties on the January 1, 2027 date use the 2027 figures for certifications effective on or after that date.
Multifamily owners who haven't implemented HOTMA keep using pre-HOTMA amounts, including the 0.06% passbook rate. HUD's inflation-adjusted figures apply only once you're following Sections 102 and 104.
Multifamily owners who implement early use the 2027 figures for 2027 certifications.
Your first mandatory Multifamily HOTMA certifications in January 2028 will use the calendar year 2028 figures, which HUD typically publishes in late summer.
Make sure your software applies figures by certification effective date and by program, not by a single portfolio-wide switch. On a layered property, that's the difference between a clean file and a correction.
The medical and disability expense phase-in only applies to families who were already receiving the deduction before your property moves to HOTMA. New move-ins go straight to the HOTMA threshold of 10% of annual income. Make sure your staff and software can tell the difference.
The 2027 COLA is out: 3.6%
Social Security announced a 3.6% cost-of-living adjustment for 2027 on October 14, 2026, up from 2.8% for 2026. It applies to Social Security and SSI benefits starting in January 2027.
Apply it as soon as you're allowed to. Some owners delay updating income after the COLA announcement, and that's an easy way to end up with incorrect tenant rent and subsidy. With 120-day notices already going out for spring recertifications, now is the time.
What to do with the extra time
Now through January 2027
Map every property and program to its HOTMA date, so layered properties don't get one rule set for everything.
Get PHA, HOME and HTF properties ready for January 1, 2027 certifications.
Apply the 3.6% COLA to recertifications.
Confirm VAWA forms show the January 31, 2028 expiration.
Review EIV procedures against the April 2026 revisions to Notice H 2023-10.
Through 2027, for Multifamily properties
Keep both TSPs on file, with the pre-HOTMA version redlined.
Remove any asset-based occupancy restrictions HOTMA doesn't allow.
Align written procedures for admissions, interims and annual recertifications with Sections 102 and 104.
Document any early HOTMA implementation by property and effective date, and annotate files where the rent override was used.
Clean up resident income and asset data before your first HOTMA certification.
Ask your software vendor for their TRACS 203A timeline, and test sample scenarios (move-in, annual, interim, zero income, complex assets) under HOTMA rules.
Build a lease changeover schedule for when the model leases are approved.
Plan staff training for the second half of 2027, when it's closest to go-live.
Late 2027
Load the calendar year 2028 figures as soon as HUD publishes them.
Run a full HOTMA annual certification end to end, from data to TRACS submission.
Spot-audit a sample of resident files using HOTMA logic.
Set a plan to review your first quarter of 2028 HOTMA certifications and fix issues quickly.
Multifamily and PHA programs: two clocks, two rulebooks
HOTMA rests on the same statutory sections for both sides, but HUD split the timelines and guidance by program.
| HUD Multifamily | PHA programs | |
|---|---|---|
| Programs | Section 8 PBRA, 202/8, 811 PRAC and related | Public Housing, HCV, PBV |
| Key guidance | Notice H 2023-10, as amended; H 2026-07 | Notice PIH 2023-27, as amended; PIH 2026-15 |
| Compliance date | January 1, 2028 | January 1, 2027 |
| What gates go-live | TRACS 203A | HUD-50058 reporting and PHA software updates |
| Policy documents | TSP, EIV policies, house rules, leases | ACOP, HCV Administrative Plan, PBV policies |
| Oversight | Contract Administrators and HUD Multifamily, through MORs | HUD PIH, through PHAS, SEMAP and audits |
If you run both, you're managing two implementation dates, two sets of policy documents and two reporting systems, and they're now a full year apart. Keeping both on one household record is what our affordable housing platform and public housing and RAD tools are built for, with HOTMA rules applied per program by each certification's effective date. EEva Compliance Intelligence can also answer program questions against each property's own compliance profile, with the rule and source cited.
Use the time
For Multifamily owners, a year is enough time to do this properly instead of in a rush. Policies, documentation, data cleanup, software testing and training can all happen on your schedule now. In late 2027, everyone will be trying to do them at once.
The extensions have been breathing room, not permission to wait.
Want to see how ExactEstate handles HOTMA calculations and TRACS submissions? Book a demo with our team.
Frequently asked questions
Has HUD extended the HOTMA compliance date again?
Yes, for Multifamily. Notice H 2026-07, issued November 2, 2026, moved the date to January 1, 2028. PHAs, HOME and HTF are still on January 1, 2027.
Will MOR reviewers cite HOTMA errors before 2028?
Before January 1, 2028, Contract Administrators will issue observations with corrective actions for HOTMA-related tenant file errors, not findings. You'll still have to fix them.
Can we pause compliance work until 2028?
No. Policies still have to match what you do on site, early implementation still has to be documented, and the work is easier to spread across 2027 than to cram into the last quarter.
When will TRACS 203A go live?
HUD hasn't set a date. The draft MAT Guide was posted September 2, 2026, and comments closed October 2. HUD has to finalize the guide before anyone can transmit 203A certifications.
Which figures should Multifamily owners use in 2027?
If you haven't implemented HOTMA, keep using pre-HOTMA amounts, including the 0.06% passbook rate. If you've implemented early, use HUD's 2027 figures: a 0.38% passbook rate, a $109,797 asset limit and a $54,898 self-certification threshold.
What's the 2027 Social Security COLA?
3.6%, announced October 14, 2026, effective with January 2027 benefits.
We manage both PHA and Multifamily properties. What changes?
Your PHA programs switch to HOTMA on January 1, 2027, while your Multifamily properties have until January 1, 2028. Make sure your software and staff apply the right rules to each program by effective date.
Sources
About the author
Matt Hoskins is the CEO of ExactEstate. He grew up in his family’s affordable housing management company and has spent his career on the operator side of LIHTC, HUD and Section 8 properties. ExactEstate is the result: compliance-first property management software for affordable housing, with TRACS submission built in.
