The Big Picture
On February 3, 2026, the U.S. Department of Housing and Urban Development (HUD) announced its final determination to further extend the deadlines for compliance with energy efficiency standards for housing financed by HUD and the U.S. Department of Agriculture (USDA).
Ultimately, Federal Housing Administration (FHA)-insured multifamily and single family, Public Housing Capital Fund and Section 8 project-based vouchers will have a new deadline of December 31, 2026, to comply with the new energy efficiency standards.
Background
On April 26, 2024, HUD and USDA issued the initial final determination which established procedures for the adoption of the 2021 International Energy Conservation Code (IECC) and the 2019 Standard 90.1: Energy Standard for Buildings, Except Low-Rise Residential Buildings (ASHRAE 90.1) as the minimum energy standards for certain types of construction and rehabilitation projects funded by the agencies.
The notice points out that, as of its posting, only five states adopted the 2021 IECC or equivalent codes, and ten states and the District of Columbia adopted the ASHRAE 90.1-2019 standards. This means that HUD- and USDA-assisted projects would be required to meet far stricter standards than the large majority of states, potentially creating additional compliance burdens and disincentivizing the utilization of these important financing tools.
On March 10, 2025, HUD initially extended the compliance dates for Federal Housing Administration (FHA)-insured multifamily and single family, Public Housing Capital Fund, Competitive Grants and Section 8 project-based voucher programs, and an additional extension was published on November 10, 2025. Competitive Grant deadlines will remain extended until their respective Notices of Funding Opportunity are released. These changes do not impact the HOME Investment Partnerships Program (HOME) or Housing Trust Fund (HTF) Programs, whose compliance dates are already in effect.
NAA’s Perspective
In light of the industry’s concerns, and because these requirements are subject to ongoing litigation, the National Apartment Association (NAA), along with the National Multifamily Housing Council (NMHC), requested that the Trump Administration decline to defend the Final Determination and continue to delay implementation pending the outcome of litigation. NAA appreciates HUD’s latest extension and thanks the administration for prioritizing deregulation and for their work to improve housing affordability and reduce housing costs. NAA remains committed to advocating for solutions to the housing supply crisis and collaborating with the Trump Administration on ways to lower the cost of providing rental housing.