HOTMA 2027: Don't Get Too Comfortable

We know how regulatory changes like HOTMA impact your daily operations. As HUD multifamily compliance software built by industry veterans, we track these updates closely because they affect how you work every single day. Not sure where your portfolio stands?

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Here's what the latest updates actually mean for your properties as of fall 2026, with about 90 days left on the clock.

Where the Date Stands Now

The multifamily HOTMA compliance date is still January 1, 2027. Housing Notice H 2025-07, published December 17, 2025, set that date for full implementation of Sections 102 and 104. No newer notice has replaced it, and HUD's Multifamily HOTMA page still lists it.

That said, HUD has acknowledged the date is currently under evaluation. Until HUD publishes a new Housing Notice, January 1, 2027 is the date that counts, and it's the date your reviewers will hold you to.

The pattern still tells a story. The original compliance date was January 1, 2025. Then July 1, 2025. Then January 1, 2026. Now January 1, 2027. Multiple extensions signal the administrative complexity housing providers face, and HUD's own systems, like TRACS 203A, are still catching up.

Whether or not HUD moves the date again, the smart play is the same: be ready for January 1, 2027. If another extension comes, you're ahead. If it doesn't, you're compliant.

What's New: TRACS 203A Is Finally in Sight

On September 2, 2026, HUD's Office of Multifamily Housing Programs posted the draft TRACS Release 203A Monthly Activity Transmission (MAT) Guide for stakeholder comment on its TRACS page. Alongside it, HUD released draft versions of the HUD-50059 certification and HUD-52670 voucher. The comment period closes October 2, 2026.

This matters because TRACS 203A is the technical backbone of multifamily HOTMA, and it's what your TRACS software will transmit on. The draft covers updated 203A instructions, adjustment and tenant rent calculations, imputed income proration and non-citizen proration. It also separates certifications processed under current 202D rules from those processed under 203A/HOTMA rules.

Here's what the draft does not do yet:

Bottom line: the pieces are moving, but slowly. That's exactly why the compliance date is under evaluation, and exactly why you shouldn't wait to see how it shakes out.

Want early rent numbers before 203A? HUD still allows owners to calculate HOTMA incomes and rents manually and enter them in TRACS 202D using the rent override function. If you go this route, annotate your tenant files to show which HOTMA change was applied.

The Fine Print You Can't Ignore

The full HOTMA compliance date has moved several times. Your paperwork expectations have not.

HUD still expects your tenant selection plan (TSP) and EIV policies and procedures to be updated for HOTMA. Reviewers are already looking for that language during MORs and other reviews.

Keep two TSPs during the transition. Owners should maintain both the current pre-HOTMA TSP and the updated HOTMA-compliant TSP. Contract Administrators review both during Management and Occupancy Reviews until TRACS 203A is released and you operate fully under HOTMA. HUD also encourages you to redline the pre-HOTMA TSP so reviewers can spot the HOTMA changes quickly.

Check your EIV master report procedures. Notice H 2023-10 was revised on April 16, 2026, and Table J1 now carries updated guidance on EIV master reports. If your written EIV procedures predate that revision, review them against Table J1.

Bottom line: if you have not updated your TSP and EIV policies with HOTMA information, you are setting yourself up for findings. Reviewers will compare what's written to what you're actually doing on site. Run your files through our Audit Readiness Checker to spot gaps before they do.

Already Jumped the Gun on HOTMA? Read This

If you started implementing pieces of HOTMA early, you're not alone. Some properties changed medical deductions, adjusted asset rules, or started using new income calculations.

Here's the issue we're seeing everywhere: properties implement parts of HOTMA in practice but never update their TSP and written procedures. The files show HOTMA logic, but there's nothing in the policy to back it up.

If you've implemented any part of HOTMA, those changes need to be documented in your TSP and aligned procedures. No exceptions. If it's in your files but not your policies, expect a finding.

Your resident files also need to tell the story. Show which parts of HOTMA you're using, and tie each practice back to HUD guidance and effective dates. If you used the TRACS 202D rent override, the file annotation should say so.

Don't be the property scrambling during a review to explain HOTMA-style processing with pre-HOTMA documentation.

The Forms Situation: Moving, But Not Done

HOTMA still has a forms gap. Here's where things stand as of September 2026:

VAWA is the one piece that's done. The updated VAWA forms are live:

Operationally: provide 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 VAWA forms don't show a January 31, 2028 expiration date, you're not using the latest versions.

When the HOTMA leases are approved, every tenant will need to sign a HOTMA-compliant lease. Start building your lease changeover schedule now so you're not sending notices to your whole rent roll at once.

The Numbers You Need for 2027

HUD posted the calendar year 2027 inflationary adjustments in August 2026. If January 1, 2027 holds, these are the figures your first HOTMA certifications will use.

Properties that haven't implemented HOTMA keep using the pre-HOTMA passbook rate of 0.06% until they do. For how the asset limit plays out at annual recerts, see our breakdown of Section 8 asset limits at reexamination.

The medical and disability expense phase-in applies only to existing residents who are already taking the deduction under the current 3% threshold as of December 31, 2026. New move-ins go straight to the HOTMA threshold. Make sure your software and staff can tell the difference.

COLA Updates: Still Not Optional

Properties are still running into issues with Social Security cost-of-living adjustments. Some owners delay or skip updating income when the new COLA is announced.

HOTMA helps here: once Social Security announces the COLA, owners can use it to project income for residents receiving Social Security or SSI. The announcement typically comes in October, which lines up well with your 120-day notice and recertification cycles.

The 2026 COLA is 2.8% (up from 2.5% in 2025). The 2027 COLA should be announced in October 2026. Apply it as soon as you're allowed to. Waiting increases the risk of incorrect tenant rent and subsidy calculations right as HOTMA certifications begin.

Your HOTMA Prep Checklist: The Final 90 Days

Here's a concise, operator-friendly checklist for October through December 2026. For a deeper dive by domain, see our full HOTMA 2027 Readiness Checklist for Multifamily.

1. Policy and Plan Updates

2. Forms, Leases, and Notices

3. Software and Data Readiness

4. Files and Documentation

5. Training and Communication

6. Operational Readiness Checks (December 2026)

Multifamily vs. PHA Programs: Different Timelines, Different Rules

HOTMA is built on the same statutory sections (102 and 104) for both sides, but HUD split the details, timelines and flexibilities by program type.

HUD Multifamily

PHA Programs

If you work across both PBRA and PHA portfolios, you're running on two implementation clocks, two policy vehicles and two systems. Each side has its own approval process, and each determines when you can actually "flip the switch" for full HOTMA certifications. Managing both on one record is exactly what our affordable housing platform and public housing and RAD tools are built for.

Community Planning and Development programs (HOME, HTF, HOPWA, CDBG) follow their own track: HUD extended their compliance date to January 1, 2027 in the Federal Register on December 30, 2025.

Use the Time Wisely

January 1, 2027 is about 90 days out. Whether HUD holds that date or moves it, the work is the same: get your policies, documentation and systems aligned now.

Reviewers are already checking for HOTMA language in your TSP and EIV policies. EIV errors account for nearly 50% of all findings. Once HOTMA is mandatory, MORs will record HOTMA-related deficiencies as findings and require corrective action.

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?

Not as of September 30, 2026. The multifamily date remains January 1, 2027 under Notice H 2025-07. HUD has said the date is under evaluation, so watch for a new Housing Notice on HUD's Multifamily HOTMA page.

Can we pause compliance work until HUD decides?

No. Reviewers already expect HOTMA-updated TSPs and EIV procedures, and properties that implemented pieces early must document them now. Keep updating policies, preparing forms, testing software and training staff.

When will TRACS 203A go live?

HUD hasn't set a date. The draft MAT Guide was posted September 2, 2026, with comments due October 2, 2026. HUD must finalize the guide before software vendors and sites can transmit 203A certifications.

What 2027 figures should we load into our software?

A 0.38% passbook rate, a $109,797 asset limit for Section 8 PBRA and 202/8, and a $54,898 asset self-certification threshold, per HUD's CY2027 inflationary adjustments.