The U.S. Department of Housing and Urban Development (HUD) has introduced two separate proposed rules that could significantly impact federally assisted housing programs. The proposals address citizenship verification requirements and potential work requirements for residents receiving rental assistance.
Citizenship Verification for Federal Housing Programs
On February 20, 2026, the U.S. Department of Housing and Urban Development (HUD) published a Notice of Proposed Rulemaking (NPRM) in the Federal Register that would require every individual living in HUD-funded housing to verify citizenship or eligible immigration status. This proposal would eliminate the current practice of allowing partial verification within a household.
Under the proposal, all household members would be required to submit documentation verifying eligible status, after which housing providers would confirm immigration status using Systematic Alien Verification for Entitlements (SAVE). Under the existing policy, current mixed-status families – households with both eligible and ineligible members – may receive prorated assistance for eligible members. The proposed rule would give household members approximately 90 days after implementation to provide documentation verifying eligibility. HUD is accepting public comments until April 21, 2026.
U.S. citizens, individuals aged 62 or older, receiving assistance before June 19, 1995, and those who do not claim eligible immigration status would be exempt from the immigration status verification requirement. U.S. citizens would still be required to sign a declaration of citizenship as part of the eligibility process. Individuals aged 62 or older receiving assistance before June 19, 1995, are considered “grandfathered” under Section 214 rules, and verifying immigration status would not be necessary.
Household members who do not claim eligible status may remain in the household, but are unable to receive housing assistance themselves. This differs from the current policy under which mixed-status families may receive prorated assistance for the household members that are eligible.
Work Requirements for Rental Assistance
On March 2, 2026, the U.S. Department of Housing and Urban Development published a proposed rule in the Federal Register as an NPRM that would allow housing authorities, as well as certain multifamily housing owners, to implement work requirements and time limits for some residents that receive federal rental assistance.
According to the proposed rule published, work requirements could be up to 40 hours per week, which Public Housing Authorities or owners adopting the policy could require eligible residents to meet through employment or other approved activities. The rule would also allow limits on the duration of assistance, potentially as short as two years for certain households. Local housing authorities and participating owners would have the discretion to decide whether to implement these policies.
Elderly residents and individuals with disabilities would generally remain exempt from the requirements. Housing providers choosing to adopt the policy would also be required to offer supportive services to assist residents in obtaining employment or participating in work-related activities. Public comments on the proposal will be accepted until May 1, 2026, after which HUD will review feedback before deciding whether to finalize the rule.
Key Takeaway for Providers
While both rules still remain proposals, their passing would introduce new compliance, verification, and administrative responsibilities for housing providers once finalized.
Work requirement compliance could require housing providers to coordinate with housing authorities or program administrators to track tenant eligibility and participation. Providers may need to maintain more detailed tenant files, update recertification procedures, and address potential lease compliance issues if tenants lose eligibility due to failure to meet the work requirements, depending on how the final rule is implemented.
Citizenship verification requirements would require documentation from every household member, including minors, which would then be verified through the SAVE (Systematic Alien Verification for Entitlements) system by property managers or housing authorities. For housing providers, this would likely result in increased paperwork, recordkeeping, and compliance procedures. Providers may also need to reassess tenant eligibility and manage potential transitions, including tenant turnover or displacement.
Operational and legal considerations could include training staff on new verification procedures, updating screening and leasing policies for HUD-assisted units, and ensuring continued compliance with fair housing and nondiscrimination laws.
While both rules remain in the proposal stage, housing providers should monitor the rulemaking process closely. If finalized, these changes could significantly affect administrative procedures, tenant eligibility verification, and day-to-day compliance obligations within federally assisted housing programs.