New Accessibility Requirement for Maryland LIHTC Projects

The Maryland Department of Housing and Community Development (DHCD) has introduced a new requirement that affects future Low Income Housing Tax Credits (LIHTC) projects, effective with the 2026 Qualified Allocation Plan (QAP) release on April 8, 2026. Under the current plan, affordable housing developments pursuing LIHTC in Maryland are required to engage a third‑party accessibility consultant to support compliance throughout the project lifecycle.

What Changed

The 2026 QAP includes a new provision requiring project teams to retain a third‑party accessibility consultant to assist with verification of compliance. The consultant’s role typically includes design review, construction-phase coordination, and documentation confirming compliance prior to project completion. The new requirement reflects a broader trend toward earlier and more formalized accessibility coordination within housing programs.

Key Dates and Milestones

  • Draft 2026 QAP Released: Early 2026
  • Potential Requirement Start: 2026 LIHTC application cycle
  • Final Adoption: April 8, 2026

For additional details regarding these requirements, please refer to the following Maryland DHCD resources:

How Code Red Consultants Can Help

Code Red Consultants works with project teams to evaluate accessibility requirements, coordinate compliance strategies across applicable standards, and support design and construction review processes. We help teams navigate complex regulatory conditions and align accessibility considerations with broader code and life safety requirements.

Application of any information provided, for any use, is at the reader’s risk and without liability to Code Red Consultants. Code Red Consultants does not warrant the accuracy of any information contained in this blog as applicable codes and standards change over time. The application, enforcement and interpretation of codes and standards may vary between Authorities Having Jurisdiction and for this reason, registered design professionals should be consulted to determine the appropriate application of codes and standards to a specific scope of work.