Latest · Rules & compliance

HUD Sets a One-Year Clock on Accessibility Claims

September 6, 2026

HUD guidance now sets a one-year deadline for filing fair housing complaints about accessibility in building design and construction, counted from the date of the initial certificate of occupancy. That clock starts whether or not anyone has noticed a problem yet.

This is not a legal team's problem alone. Marketing and leasing are the first people talking about a new building publicly, and the first people generating the paper trail that will matter if a claim comes in during that window. If your team can't produce, on request, the certificate of occupancy date and documentation that unit specs met accessibility requirements at turnover, that's a gap worth closing before it's tested.

What to actually do: pull the certificate of occupancy date for every property that opened in the last year and confirm it's logged somewhere marketing and leasing can find it, not just buried in a construction file. Check that your leasing team's model unit walkthroughs, listing photos, and floor plan disclosures match what was actually built and don't imply features that aren't there. If you're leasing up a new community right now, treat day one of occupancy as the start of a deadline, not just a marketing milestone.

This guidance doesn't change what accessible construction requires. It changes how long someone has to say you got it wrong. Documentation habits that were "nice to have" are now the difference between a closed claim and an open one.

Source: Multifamily Dive, September 4, 2026