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HOTMA Compliance Updates – as of 1/5/26

We have received information from many Housing Finance Agencies (HFAs) about their plans to implement the Housing Opportunity Through Modernization Act (HOTMA) for the Low-Income Housing Tax Credit (LIHTC) program. Below, you will find the status of states that have either confirmed in writing or discussed adoption of HOTMA. We will continue to update this information as we learn more. It is important to note that this information is subject to change, HUD extended the HOTMA compliance date from January 1, 2026, to January 1, 2027 in late December 2025, and agencies may revise their mandatory timelines accordingly. 

Please note, some states have released new Tenant Income Certifications to update the passbook rate, however, if additional HOTMA guidance or instruction has not been released those HFAs will not appear on the list below.  

State/Territory   Mandatory HOTMA Adoption Status*   Additional Notes  
NCSHA   -   As of December 1, 2025, NCSHA has released updated model forms. This includes changes to the Asset Self-Certification Worksheet. Please note that this TIC includes tax refund considerations which will require an update to Voyager Affordable plug-ins.  
Alabama   July 1, 2025  In September of 2024, Alabama confirmed they will be moving forward with the NCSHA TIC.  
Alaska   September 1, 2024  On April 12, 2024, AHFC stated that “all Programs are required to implement these changes no later than September 1, 2024. While implementation is required, no noncompliance will be identified until January 1, 2025, to allow Owners, Partners, and Manager’s time to complete training, update internal policies and procedures, and complete implementation.”  
Arizona   January 1, 2026  On June 3, 2025, Arizona extended the HOTMA compliance date to 01/01/2026 following HUD Guidance. ADOH will be moving forward with the implementation of HOTMA. All Multifamily Programs must be fully compliant for certifications effective on or after January 1, 2026. For these certifications, non-compliance for LIHTC projects will be reported to the IRS after January 1, 2026. 
Arkansas   January 1, 2027  ADFA has released a TIC that has minor edits to the NCSHA TIC. AFDA released a draft Affordable Housing Compliance Manual that includes HOTMA guidance. ADFA has released their new HOTMA forms. AFDA is mandating the implementation of HOTMA to align with HUD effective 01/01/2027, unless a project is layered with a program that had already mandated the implementation of HOTMA, such as Rural Development.     
California   January 1, 2027  CTCAC has indicated that implementation will not be mandatory effective January 1, 2027. CTCAC’s monitoring guidance for HOTMA policies is available to projects that opt to implement the new policies beginning January 1, 2024. Implementation can be partial or full. Income and asset documentation shall be collected within 120 days of January 1, 2027.  Please note that CTCAC has added new fields to the TIC related to assets which will require an update to Voyager Affordable plug-ins.  
Connecticut   January 1, 2027  On 09/24/2024, Spectrum updated its website to use the NCSHA TIC. Please note that this TIC includes tax refund considerations which will require an update to Voyager Affordable plug-ins.  
Colorado   January 1, 2026  On 06/24/2024, CHFA released an updated manual and HOTMA-compliant Tenant Income Certification. On 07/14/2025, CHFA decided to extend the mandatory implementation date of HOTMA to January 1, 2026, for the Housing Tax Credit and CHFA multifamily loan programs. CHFA strongly encourages HOTMA implementation sooner when possible, for all Housing Tax Credit and CHFA Loan developments not layered with Section 8, HOME, or comparable programs. Prior to January 1, 2026, noncompliance findings will not be issued for HOTMA-related tenant file errors during Program Compliance reviews. Instead, the Program Compliance Officer (PCO) will issue observations.  
Delaware   January 1, 2027  On 01/04/2024 Spectrum Compliance website for DE was updated with a HOTMA updated Tenant Income Certification. Delaware has pushed back mandatory compliance to 01/01/2026 to align with HUD.  
Georgia   January 1, 2027   DCA has announced a HOTMA effective date of 01/01/2024, with a compliance date for implementation will be no later than January 1, 2027. GDCA announced on January 2, 2026 that it is extending its HOTMA implantation readiness plan until April 1, 2026. HOTMA requirements will not be mandatorily enforced until January 1, 2027, consistent with HUD’s revised timeline. DCA will continue to focus on education, technical assistance, and readiness, rather than enforcement during this extended transition period. HOTMA-related deficiencies identified through compliance monitoring will not result in the issuance of any IRS 8823 Forms or formal compliance findings during the implementation readiness period, provided no other noncompliance issues are present. 
Hawaii   January 1, 2027  On December 12, 2023, HHFDC held an affordable program training led by Spectrum Compliance which included HOTMA regulation showing an effective date of 01/01/2024. In 09/2024 Spectrum posted a new HOTMA compliant TIC which has now been programmed.  
Idaho   January 1, 2025  IHFA has posted a new HOTMA-compliant TIC. Please note that this TIC includes tax refund considerations which will require an update to Voyager Affordable plug-ins.  Units layered with Project Based Section 8 are exempt from HOTMA until January 1, 2027. Units occupied by tenants with a Housing Choice Voucher are NOT exempt from HOTMA. 
Illinois   January 1, 2025  On 09/10/2024 IHDA released new forms for HOTMA including a TIC, with an implementation effective on 01/01/2025.  
Indiana   January 1, 2026  IHDCA has updated forms for HOTMA on April 1, 2024, including a HOTMA TIC.   IHCDA will note HOTMA related noncompliance issues identified prior to January 1, 2026, and will require necessary corrective action, as applicable. However, IHCDA will not impose penalties for HOTMA specific issues identified prior to January 1, 2026 (i.e., will not issue 8823s, suspend partners, or impose fines) for items specifically linked to HOTMA changes. 
Iowa   July 1, 2026  IFA is requiring that all LIHTC, HOME, and NHTF projects to begin implementing HOTMA with the latest IFA forms starting January 1, 2026.  IFA will have a grace period on uncorrected issues through July 1, 2026.  Please note this HOTMA implementation requirement will not include projects with Section 8 project based rental assistance at this time. IFA has posted a new HOTMA-compliant TIC (almost identical to NCSHA’s version), Compliance Manual for LIHTC, HOME, and NHTF, and HOTMA-compliant forms. Please note that this TIC includes tax refund considerations which will require an update to Voyager Affordable plug-ins.  
Kansas   January 1, 2024  On November 10, 2023, Kansas Housing released an updated TIC and compliance manual draft, confirming they will adopt HOTMA on January 1, 2024.  
Kentucky   January 1, 2026  In December 2023 KHC issued HOTMA Guidance and an updated TIC. The guidance state “Changes should be implemented for all households moving in or recertifying after January 1, 2024.” Since HUD delayed HOTMA implementation, KHC will not be taking enforcement actions for any HOTMA file deficiency prior to January 1, 2027. The Multifamily Compliance Department of Kentucky Housing Corporation (KHC) implemented Housing Opportunity Through Modernization Act (HOTMA) requirements on January 1, 2024. At that time, we encouraged all our partners to start becoming familiar with HOTMA and then begin making the necessary changes in policies and procedures so full implementation could begin January 1, 2026. Since that time, the U.S. Department of Housing and Urban Development (HUD) has delayed full HOTMA implementation until January 1, 2027. 
Louisiana   January 1, 2026  Louisiana has provided a HOTMA TIC (similar to NCSHA’s version) and previously announced implementation of HOTMA effective for January 1, 2025, move-ins and annual recertifications with an effective date of April 1, 2025. Currently LHC is not requiring HOTMA but does allow implementation at the property level.   Please note that this TIC includes tax refund considerations which will require an update to Voyager Affordable plug-ins.  
Maine   January 1, 2027  Maine announced in Asset Management Notice #2025-08 that the agency intends to delay HOTMA implementation to align with HUD’s timeline; HUD’s current implementation for HOTMA is January 1, 2027. No HOTMA TIC has been released.  
Maryland   January 1, 2026  Maryland acknowledged HUD’s extension to 1/1/2026 and has recommended the use of the NCSHA TIC for HOTMA compliance. The Department will extend the interim guidance established in Multifamily Notice 24-01 until the new implementation date of 1/1/2026.  
Massachusetts   January 1, 2027  In 09/2024 Spectrum updated their website with a new HOTMA compliant TIC. Most recent published guidance was released in March 2024.  
Michigan   January 8, 2024  MSHDA released a new memo and HOTMA TIC on January 3rd, 2024, with guidance that states “MSHDA is looking to have all HOTMA changes implemented by 1/8/2024 for any certifications completed on or after that date.” MSHDA has requested that all LIHTC properties begin following HOTMA as of 1/1/2024, however until HUD officially starts enforcing HOTMA the agency will only be reporting issues with HOTMA findings as “Observations.” 
Minnesota   January 1, 2027  Minnesota Housing Finance Agency’s (MHFA) Housing Tax Credit Compliance Guide states that for certifications and recertifications effective on or after July 1, 2025, or such later date determined by HUD when the Housing Opportunities Through Modernization Act (HOTMA) must be fully implemented. Per the HUD delay, HOTMA implementation will be mandatory for certifications effective January 1, 2027. MHFA and sub-allocator Affordable Housing Connection (AHC) have confirmed that sites are permitted to the NCSHA TIC for their HOME, National Housing Trust Funds, MARIF, HOPWA, and Housing Tax Credits programs.  
Mississippi   January 1, 2027    MHC has posted a new HOTMA-compliant TIC as of 09/2024. MHC allowed implementation of HOTMA as of 6/1/2024 but does not currently have a final implementation date.  
Missouri   July 1, 2025  On November 20, 2023, the Missouri Housing Development Commission published an updated TIC and HOTMA Manual to adopt HOTMA as of January 1, 2024. On September 20, 2024, MHDC announced that certifications with an effective date of July 1, 2025, or later must comply with HOTMA requirements (Notice H 2023–10).  
Montana   January 1, 2024  Montana Housing provided an updated copy of their TIC on 10/08/2024.  
Nevada   January 1, 2027  Nevada Housing Division has stated that the agency is monitoring for HOTMA regulations but are not currently reporting any findings. Nevada Housing Division will align to HUD’s deadline of January 1, 2027.   NHD has released a HOTMA TIC, which has now been programmed.  
New Hampshire   January 1, 2027  In December 2025, NH Housing announced all multifamily properties will be required to implement the Housing Opportunity Through Modernization Act (HOTMA) Final Rule no later than January 1, 2027. Unless otherwise extended by HUD’s Office of Multifamily Housing (MFH), this requirement applies to all properties in New Hampshire Housing’s multifamily portfolio.   In a separate memo dated April 10, 2025, NH Housing TIC stated the agency will be discontinued and a Tenant Income Certification (TIC) produced by the owner/agent’s software or other HOTMA compliant TIC should be used.  
New Jersey   January 1, 2026  New Jersey has stated that HOTMA changes should be implemented by January 1, 2026.   The December 11, 2025, edition of the Asset Management Bulletin, NJHFA stated pursuant to HUD Notice H 2025-03 the implementation date of Notice H 2023-10 (HOTMA) has been revised from July 1, 2025, to January 1, 2026. Although the HOTMA implementation date has been extended, if the changes have already been implemented at your property, the Agency will perform the Tenant File Audit per the HOTMA regulations and NJHMFA’s specific policies outlined in the bulletin.  Please note that this TIC includes tax refund considerations which will require an update to Voyager Affordable plug-ins.  
New Mexico   January 1, 2027  In August 2025, Housing New Mexico | MFA released its Low-Income Housing Tax Credit Compliance Plan, which includes HOTMA compliance. The agency has also released a HOTMA-compliant TIC and forms.  Housing New Mexico has stated that HOTMA is to be implemented in its entirety with the 1/1/2026 implementation date unless there are announced delays. 
New York  
(HCR)  		 January 1, 2026  HOTMA guidance was released in a memo dated 12/9/24. On 6/2/25 the agency updated their memo to reflect that they will implement their HOTMA policies effective1/1/26.   Please note that this TIC includes tax refund considerations which will require an update to Voyager Affordable plug-ins.  
New York  
(HDC)  		 July 1, 2025  HDC has released a new TIC and their 2025 Marketing Handbook FAQ states that recerts effective 7/1/2025 and later should be fully compliant with the new forms and HOTMA rules and that the agencies will continue to accept both old and new forms for recertifications effective in April, May, and June.  
North Carolina   July 1, 2025  The North Carolina Housing Finance Agency has stated that HOTMA is required for all certifications effective 7/1/2025 or later (effective date not signature date). An updated TIC was posted on NCHFA’s website on 07/24/2024.  
North Dakota   January 1, 2024  NDHFA will note HOTMA related non-compliance issues identified in calendar year 2024 and will require necessary corrective action. However, NDHFA will not impose penalties or HOTMA specific issues during calendar year 2024- i.e. will not issue 8823s for items specifically linked to HOTMA changes. As of 10/2024, North Dakota has adopted the NCSHA TIC. Please note that this TIC includes tax refund considerations which will require an update to Voyager Affordable plug-ins.  
Ohio   May 1, 2025  On September 26, 2024, Ohio revised their timeline in response to HUD’s announcement stating “OHFA will implement HOTMA on January 1, 2025, however, mandatory use of HOTMA rules will only be applicable for initial tenant certifications and recertifications effective May 1, 2025, onward.”  As of 5/5/2025, OHFA released its HOTMA-compliant Tenant Income Certification (TIC). All certifications effective 5/1/2025 or later must meet HOTMA requirements. Tenant events entered into DevCo before 5/5/2025 must be re-entered using the new TIC format, as data from the previous version does not transfer.  Per OHFA’s guidance issued on 7/23/2025, owners/management agents should not print or have tenants sign the re-entered HOTMA TIC solely for format alignment. Instead, a clarification record must be placed in the tenant file explaining the re-entry was due to the TIC update. If the HOTMA TIC was printed and signed before the 7/23/2025 guidance, it is considered an error. A clarification record must state it was signed prior to OHFA’s updated instructions.  
Oklahoma   January 1, 2025  On December 18, 2024, OHFA announced that the HOTMA implementation date would be January 1, 2025. The agency’s website has been updated with new HOTMA forms. Please note that this TIC includes tax refund considerations which will require an update to Voyager Affordable plug-ins.  
Oregon   January 1, 2025  Oregon plans to fully implement HOTMA and begin monitoring under HOTMA guidelines effective January 1, 2025; however, from January 1, 2025, through June 30, 2025, findings specific to new HOTMA requirements will be documented as “observations.”   Please note that this TIC includes tax refund considerations which will require an update to Voyager Affordable plug-ins.  
Puerto Rico   January 1, 2026  Puerto Rico Housing Finance Authority (PRHFA) has stated the implementation of HOTMA will be mandatory for all new move-ins and recertifications effective January 1, 2026. The agency has stated they are working to update the Compliance Monitoring Plan to be issued in 2026.  
Pennsylvania   July 1, 2025  Pennsylvania Housing Finance Agency (PHFA) announced during their training that they are adopting (HOTMA) and are developing a new Tenant Income Certification (TIC) form. PHFA’s HOTMA implementation date is July 1, 2025. PHFA published updated HOTMA guidance on 8/12/2025.  
Rhode Island   January 1, 2026  On 10/04/2024 Rhode Island confirmed they will be adopting the NCSHA TIC. Rhode Island’s HOTMA implementation date will be 1/1/2026. In a memo from July 18, 2025, the agency stated that a mandatory date will be forthcoming for HOME and LIHTC developments and we will give 3 months’ notice to comply. Please note that this TIC includes tax refund considerations which will require an update to Voyager Affordable plug-ins.  
South Carolina   January 1, 2025  South Carolina Finance and Development Authority confirmed in July 2024 that HOTMA will be implemented effective October 1, 2024; however, the HOTMA policy will not be enforced until January 1, 2025. On 08/28/2024, confirmed they will be adopting the NCSHA TIC. Please note that this TIC includes tax refund considerations which will require an update to Voyager Affordable plug-ins.     
South Dakota   July 1, 2025  As of October 2024, South Dakota Housing Development Authority published HOTMA guidance, and a HOTMA compliant TIC was posted in November 2024. SDHDA confirmed that HOTMA compliance would be mandatory effective July 1, 2025. Please note that this TIC includes tax refund considerations which will require an update to Voyager Affordable plug-ins.  
Tennessee   January 1, 2025  THDA announced that all HOTMA changes as described should be implemented or begin on January 1, 2025. Pre-planned actions with an effective date of January 1, 2025, through April 30, 2025, such as annual recertifications, will be subject to phased-in considerations. Please note that this TIC includes tax refund considerations which will require an update to Voyager Affordable plug-ins.  
Texas   January 1, 2024  Texas Department of Housing and Community Affairs stated during a training session that they will begin conducting audits for HOTMA starting on January 1, 2024.  
Utah   July 1, 2025  On December 22, 2025, the agency stated in an email to owners that while HUD has extended the HOTMA implementation deadline for HUD-assisted properties to January 1, 2027, UHC will not be extending the deadline. All properties monitored by UHC are still required to be fully compliant with HOTMA effective January 1, 2026. For projects layered with HUD funding that elect not to implement HOTMA on the HUD side, HOTMA requirements will still apply to the LIHTC program. As a result, these projects may be required to maintain separate files and compliance procedures for HUD and LIHTC purposes. UHC has released a new TIC and Under Asset Self Certification form. UHC Guidance from memo on March 12, 2024: “UHC will not enforce HOTMA-related file errors (i.e., will not issue 8823’s) discovered prior to January 1, 2025.”  On September 19, 2025, UHC released the updated Compliance Manual that includes important updates related to HOTMA.  
Vermont   July 1, 2025  Vermont has released a HOTMA compliant TIC using the NCSHA template and announced a HOTMA compliance date of 07/01/2025. Please note that this TIC includes tax refund considerations which will require an update to Voyager Affordable plug-ins.  
Virginia   July 1, 2025  Virginia Housing has released a new TIC effective January 1, 2024.   As of 10/18/2024 the agency has delayed mandatory compliance with HOTMA. HOTMA compliance will be required for all tenant income certifications by July 1, 2025, or the date required for all programs by HUD or the IRS. On November 7, 2025, Yardi confirmed with VHDA that the Virginia Housing specific TIC is no longer required and the NCSHA TIC can be used.  
Washington   January 1, 2025  On January 9, 2025, WSHFC released a new HOTMA compliance TIC. Washington has stated that HOTMA changes should be implemented by January 1, 2025.    
West Virginia   January 1, 2027  On 01/04/2024 Spectrum Compliance website for WV was updated with a HOTMA updated Tenant Income Certification.  
Wisconsin   January 1, 2025  HOTMA-compliant TIC was released on 04/05/2024, and this document is now available. Guidance from WHEDA: “The effective date for HOTMA implementation in Housing Tax Credit (HTC), aka Low-Income Housing Tax Credit (LIHTC), and WHEDA Financed Properties is 01/01/2024. However, some changes may be delayed due to pending updates by major software vendors.”  
Wyoming   January 1, 2026  WDCA has posted a HOTMA-compliant TIC and confirmed that they are targeting 01/01/2026 for an implementation date. A new HOTMA manual was released in August 2025 on WCDA’s website.  

*Note: Implementation dates reflect the agency’s current published guidance and may change. HUD extended the HOTMA compliance date from January 1, 2026, to January 1, 2027 in late December 2025, and agencies may revise their mandatory timelines accordingly. 

In addition to tracking Housing Finance Agencies, we are closely monitoring HUD’s HOTMA resource page and newsletters, along with RHS resources and training, for updates related to all HUD multifamily programs and Rural Development.  

Agency   HOTMA Adoption Status   Additional Notes  
HUD   January 1, 2027  On December 17, 2025, HUD extended the HOTMA implementation deadline to January 1, 2027.    On September 17, 2025 HUD published in the Federal Register a 30-day notice of proposed information collection for the Owner’s Certification with HUD Tenant Eligibility and Rent Procedures, this includes the revised HUD-50059, HUD-50059 Instructions, HUD-50059-A, HUD-50059-A, Instructions, HUD-9887/9887-A, HUD-27061-H, HUD-92236, HUD-90100, HUD-90101, HUD-90102, HUD-90104, HUD-90105-a, HUD-90105-b, HUD-90105-c, HUD-90105-d, HUD-90106, HUD-90011 (Enterprise Income Verification (EIV) System Multifamily Housing Coordinator Access Authorization Form), HUD-90012 (Enterprise Income Verification (EIV) System User Access Authorization Form), EIV and You Brochure, Resident Rights and Responsibilities Brochure, and Fact Sheet for HUD Assisted Residents. The comment period is now closed and we continue to monitor OMB and HUD for further announcements. Previously, HUD updated the requirement for Tenant Selection Plan and EIV policies and procedures to be completed by May 31, 2024.  In April 2025, updated versions of VAWA 5380 and 5382 were posted. While there is still uncertainty around HUD’s timeline for implementing the policy and procedural changes tied to these revised forms, Yardi has already begun updating our systems to support the new forms.   
HOME  
HTF  
HOPWA  
CDBG  
ESG  
CoC CPD  		 January 1, 2027  On December 30, 2025, HUD announced in the Federal Register that they are extending the compliance date for the HOME Investment Partnerships Program (‘‘HOME’’), HOME-American Rescue Plan program, Housing Trust Fund (‘‘HTF’’), Housing Opportunities for Persons With AIDS (‘‘HOPWA’’), Community Development Block Grant Program (‘‘CDBG’’), Emergency Solution Grants (ESG), Continuum of Care (CoC) programs, and CPD programs funded through competitive process (‘‘CPD programs’’) until January 1, 2027.  Please note: In certain situations, housing finance agencies oversee the HOME program. Therefore, timelines and expectations should be confirmed with them separately.  
Rural Development (RD)   July 1, 2025  To align with HUD, Rural Housing Service (RHS) is extending full implementation of applicable HOTMA regulations until July 1, 2025. All MFH tenant certifications effective on or after July 1, 2025, must comply with HOTMA requirements. On 06/13/2024, RHS Multifamily Housing published an updated CHAPTER 6: Project Occupancy to outline new tenant eligibility requirements.  

Based on the considerable number of local programs and the limited guidance available, we are unable to track their status regarding HOTMA.  

Voyager clients: For more details, please log into Client Central and review the recorded webinars available under Product Resources -> Video Library -> Filter on Affordable.  

Breeze clients: For more details, please log into Breeze and review Help Center -> Instructional Webinars.  

RightSource clients: For more details, please log into RightSource Help and review the new HOTMA section.  

For additional information regarding HOTMA please visit:  

  • HUD’s Multifamily HOTMA Resources  
  • https://www.hud.gov/hud-partners/multifamily-hotma  
  • National Center for Housing Management  
  • NCSHA