New income and asset calculations for Section 8 residents are underway. 

The Big Picture 

On May 14, 2026, the U.S. Department of Housing and Urban Development (HUD) published Notice PIH 2026-15, which announced that the agency will enforce compliance with sections 102 and 104 of the Housing Opportunity Through Modernization Act of 2026 (HOTMA) for most public housing agencies (PHAs) beginning January 1, 2027. Broadly, these sections change income calculations and reviews for participants in the Section 8 Housing Choice Voucher (HCV) and public housing programs. 

Background 

HOTMA, signed into law in 2016, amended several HUD-administered housing programs including the Section 8 HCV and Project-Based Rental Assistance (PBRA) programs, public housing and other programs administered by other federal agencies. Initially, HUD allowed PHAs to begin compliance with sections 102 and 104 between January 1, 2024, and January 1, 2025. However, digital infrastructure development delays led HUD to only enforce certain aspects of those sections within that timeframe. 

Deeper Dive 

With the publication of this notice, HUD is setting January 1, 2027, as the compliance deadline for all aspects of sections 102 and 104 of HOTMA for all PHAs administering the HCV, Project-Based Voucher, Moderate Rehabilitation, Moderate Rehabilitation Single Room Occupancy and public housing programs. 

PHAs that participate in the Moving to Work (MTW) demonstration program or those that currently exclusively use the HUD Family Reporting Software are not included in this list. HUD will issue further guidance for those properties at a later date. 

Section 102 of HOTMA requires that a PHA conduct income reviews of assisted families upon initial provision of assistance, annually thereafter, and any time it is estimated that the family’s income and deductions have increased by 10 percent. Meanwhile, an assisted family can request an additional review anytime it is estimated that their income and deductions have decreased by 10 percent. The PHA must follow specified requirements in calculating income and deductions. 

Section 104 sets an annual asset limit of $100,000 (adjusted for inflation) for assisted families and prohibits assistance from going to families with an ownership interest in property that is suitable for occupancy, with some exceptions. 

Industry Impact 

This notice does not impose any affirmative requirements on housing provider participants in Section 8 programs. However, it may impact eligibility of current or future residents, as PHAs have so far only been required to include income exclusions and de minimis errors in their examinations. 

NAA’s Perspective 

The National Apartment Association (NAA) appreciates the Trump Administration’s goals of ensuring that housing assistance is provided to households that need it most. As HUD further streamlines its policies and reduces regulatory barriers, NAA will continue to serve as the industry’s voice to federal policymakers.