HUD Office of Housing Sends Letter with Citizenship Status Verification Reminders

On January 12, 2026, HUD sent a letter to owners and agents (O/As) of Section 8 Project-Based Rental Assistance (PBRA), reminding them of their requirements to document and verify citizenship and prorate assistance where required. This letter is a reminder of existing law, and a discussion of new actions by HUD in another HUD office follows after a discussion of this letter’s contents. The letter has five main sections.

1. This section provides an overview of the current requirements to verify eligible immigration or citizenship status. Citizenship or eligible immigration status must be determined for any family member prior to admission to the PBRA program. U.S. citizens and eligible noncitizens must sign a declaration of their status. Eligible noncitizens must provide certain other supporting documentation. Those family members that do not sign a declaration of their status or provide the required supporting documentation will be considered ineligible for housing assistance. This section includes an overview of requirements for O/As to use the Systematic Alien Verification for Entitlements (SAVE) system.
2. O/As are reminded to prorate assistance in certain circumstances. In instances where one or more members of a family do not contend immigration status, and other family members establish their citizenship or eligible immigration status, the family may be eligible for continued assistance, temporary deferral of termination, or prorated assistance. If the O/A determines that a family has knowingly permitted an ineligible noncitizen—other than any ineligible noncitizen listed on the lease—to permanently reside in the unit, then the family’s lease must be terminated. A footnote in the overview of the letter states that HUD is working on changing these regulations and that a rule is likely to be published “in the first quarter of 2026.” A draft version of therule was leaked in September 2025.
3. This section requires O/As to collect social security numbers for all applicants except ineligible noncitizens and discusses circumstances that allow for alternate ID requirements using TRACS. It also provides an overview of monthly Enterprise Income Verification (EIV) report requirements.
4. The fourth provides a list of regulatory and guidance documents and resources for O/As.
5. Finally, the last section is an appendix that provides a crosswalk between Systematic Alien Verification for Entitlements (SAVE) system responses and a person’s eligibility for HUD assistance (i.e., the appendix helps categorize the response from SAVE when verifying immigration status into whether the individual is eligible, ineligible, or requires more information for HUD assistance).

NAHRO strongly advises its members to carefully read through the letter, the underlying regulations, the guidance referenced, and to examine the appendix providing the crosswalk between SAVE statuses and eligibility for assistance. Please note that this article is a summary of the letter and does not reiterate every point in the letter, so reading the full letter is crucial.

This letter to PBRA O/As resembles a similar letter sent to Public Housing Agencies (PHAs) in December 2025 by HUD’s Office of Public and Indian Housing (PIH). That December PIH letter was followed by a January 2026 letter to PHAs regarding SAVE status discrepancies. As of this writing, PBRA O/As have not received a similar letter regarding SAVE reports. NAHRO will alert members if such a letter is published.

Find the PBRA reminder letter here.