HUD Proposes Work Requirements, Term Limits Opt-In
Learn more about how this may impact subsidized housing.
BY EMILY HOWARD
APARTMENT ADVOCATE
NATIONAL APARTMENT ASSOCIATION
THE BIG PICTURE
On March 1, 2026, the Department of Housing and Development( HUD) released its notice of proposed rulemaking( NPRM), Establishing Flexibility for Implementation of Work Requirements and Term Limits, that would revise HUD regulations to authorize Public Housing Agencies( PHAs) and covered multifamily housing owners to opt into work requirements and term limits for federal housing assistance.
If imposed, these new policies would apply to non-elderly, non-disabled renters who reside in public housing or receive assistance through the Housing Choice Voucher( HCV), Project-Based Voucher( PBV) or Project-Based Rental Assistance( PBRA) programs. Stakeholders have 60 days from the date of publication( until May 1, 2026) to participate in the public comment period for this rule.
WORK REQUIREMENTS
As written, the rule would allow PHAs and covered housing providers to require“ work-eligible adults” to work up to 40 hours per week as a condition of continued occupancy in public housing to continue receiving federal housing assistance. This rule would create a new definition for“ workeligible adults” to mean:
"[ a ] n assisted family member aged 18 to 61, excluding persons with a disability as defined in 24 CFR 5.403 or a primary caretaker of such individual, or who are pregnant, or who are the primary caretaker for a child under 6 years of age or for temporarily incapacitated individuals, or who are enrolled as a student in an institution of higher education as defined in section 102 of the Higher Education Act of 1965."
Required“ work activities” for the purposes of this rule are also defined, including public and private-sector employment, job training and workrelated education. The rule also mandates certain procedures for PHAs and covered housing providers if these requirements are imposed, such as tenant notification requirements.
TERM LIMITS
The rule permits PHAs and covered housing providers to establish term limits for federal housing assistance, of at least two years or more for non-elderly, non-disabled renter households receiving HCV, PBRA or PBV assistance or residing in public housing. If imposed, HUD-assisted households would become subject to the term limit policy starting on the date upon which the PHA or covered housing provider’ s term limits policy becomes effective. The rule provides PHAs with flexibility to implement different term limits within and between their public housing, HCV, PBRA and PBV programs“ to address local needs and goals.”
Similar to work requirements, the rule mandates certain procedures for PHAs and covered housing providers if these requirements are imposed, such as tenant notification requirements. According to the proposed regulations, PHAs and covered housing providers that elect to adopt a term limit policy would also be required to offer supportive services to assist families to prepare for the termination of assistance, for example, working with a partner organization to help make referrals to a local workforce development center or other community service provider.
NAA’ S PERSPECTIVE
The National Apartment Association( NAA) is digesting the nearly 60-page proposal now to better understand impacts to rental housing providers, for example, if individual PHAs elect to adopt these policies. NAA is preparing to submit comments by the public comment period deadline to elevate our perspective and continues our advocacy with the Trump Administration and Congress to ensure the industry’ s perspective is heard and represented in federal housing policy conversations. www. aamdhq. org TRENDS MARCH 2026 | 51