--- title: Executive Compensation Reporting for Public Housing Authorities description: Public Housing Authorities (PHAs) next reporting cycle is 2026, report executive compensation using HUD-Form 52725. image: https://blog.becpas.com/hubfs/Executive%20Compensation%20Reporting%20for%20Public%20Housing%20Authorities.jpg --- [Twitter ** ](https://www.facebook.com/BrownEdwardsCPAs?utm_source=BE+Website&utm_medium=Website+Icon&utm_campaign=BE+Website+Social+Icon&utm_content=Facebook) [Facebook-f ** ](https://www.linkedin.com/company/brown-edwards/?utm_source=BE+Website&utm_medium=Website+Icon&utm_campaign=BE+Website+Social+Icon&utm_content=LinkedIn) [Linkedin ** ](https://www.youtube.com/channel/UC3ReCSn6AFfdQiCUsH4oopA?utm_source=BE+Website&utm_medium=Website+Icon&utm_campaign=BE+Website+Social+Icon&utm_content=YouTube) [Youtube ** ](https://www.youtube.com/channel/UC3ReCSn6AFfdQiCUsH4oopA?utm_source=BE+Website&utm_medium=Website+Icon&utm_campaign=BE+Website+Social+Icon&utm_content=YouTube) [ Client Portal ](https://becpas.sharefile.com/Authentication/Login) [ Make A Payment ](https://becpas.com/payments/) [ Request Proposal ](https://becpas.com/request-for-proposal/) ![](https://blog.becpas.com/hubfs/Executive%20Compensation%20Reporting%20for%20Public%20Housing%20Authorities.jpg) # Executive Compensation Reporting for Public Housing Authorities Published by [ Brian Alten ](https://blog.becpas.com/author/brian-alten) on Mar 6, 2026 8:00:01 AM Every three years, Public Housing Authorities (PHAs) are required to report executive compensation to the Department of Housing &Urban Development (HUD) using [HUD-Form 52725](https://www.hud.gov/sites/dfiles/OCHCO/documents/52725.xlsx), and the next reporting cycle is coming upin 2026. The last time PHAs submitted this information was in 2023 for calendar year 2022, as outlined in [PIH Notice 2023-05](https://www.hud.gov/sites/dfiles/OCHCO/documents/2023-05pihn.pdf). In 2023, the submission window was April 1 to June 30, so we can expect a similar timeline for reporting 2025compensation data in 2026. HUD will notify PHAs when it is time to begin the reporting process. The process is handled electronically through HUD’s secure systems. As stated in [PIH Notice 2023-05](https://www.hud.gov/sites/dfiles/OCHCO/documents/2023-05pihn.pdf), *"The reporting requirements apply to all PHAs that administer a public housing or housing choice voucher program, regardless of the amount of compensation paid to an employee. This includes PHAs that have converted their entire public housing inventory via the Rental Assistance Demonstration (RAD) Program but still received funding sourced from Section 8or Section 9 (Capital Fund & LIPH) in [CY2025]. There are no exemptions from these requirements. The reporting requirements also apply to Moving to Work Demonstration Program (MTW) agencies.* *A PHA is defined in 24 CFR 5.100 and also includes any public or private nonprofit entity that was administering a Section 8tenant-based assistance program pursuant to a contract with HUD or a PHA on or prior to October 21, 1998, as noted in 24 CFR § 982.4(b)."* ## Hud Form 52725 Consists of Three Sections: Section I - PHA Information  - Name of PHA, PHA Code, Fiscal Year (FY), etc. **Section II **– Calendar year employee compensation data - The top management official (e.g., the Executive Director, Chief Executive Officer (CEO), or person with similar duties). - The top financial/accounting official (e.g., the Chief Financial Officer (CFO) / Chief Accounting Officer, or person with similar duties). - All individuals who are paid an annual salary (including bonus) above the prevailing salary for [level IV of the Executive Schedule ($195,200 for CY2025)](https://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/salary-tables/pdf/2025/EX.pdf). The salary cap for [CY 2026 level IV of the Executive Schedule is $197,200](https://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/salary-tables/pdf/2026/EX.pdf). **Section III **– For individuals reported in section II that received cash compensation that was not reported on IRS form W-2 (for example, when cash compensation is reported on IRS form 1099, the covered individual does not receive a W-2). Section II will require the most work from the PHA when entering detailed data regarding the employee’s name, position, salary amount,allocation to Section 8, Section 9 and other funds as well as incentive and bonus amounts. Other items to note include, if the top management official and the top financial/accounting official are the same person, the PHA is to report information for that person and the next highest paid employee. A PHA that has neither a top management official nor financial/accounting official must report compensation for its two highest paid employees. It is likely that appropriations language remain consistent with previous years, and the following language will remain the same: *"no tenant-based section 8 or section 9 funds may be used by any public housing agency for any amount of salary, including bonuses, for the chief executive officer of which, or any other official or employee of which, that exceeds the annual rate of basic pay payable for a position at level IV of the Executive Schedule at any time during any public housing agency fiscal year."* This means that salaries paid to staff funded from Section 8and/or Section 9 cannot exceed level IV of the Executive Schedule and also includes fees that PHAs earned in the COCC derived from Section 8 and Section 9after the implementation of asset management. Since these fees were collected from Section 8 or Section 9funding, it is Congress’ mandate that any fees a PHA collects that originate from Section 8 or Section 9 remain subject to this limitation and counts toward the amounts limited by Congress during the PHA’s FY. Refer to [PIHNotice 2016-14](https://www.hud.gov/sites/documents/16-14pihn.pdf) for more information. The term **covered individuals** includes: The term **covered individuals** does **not **include: The term **chief executive officer** includes: The term **any other official or employee** includes: As provided by Congressional appropriations in FFY 2015,salaries (including bonuses) are subject to the restriction. Overtime and benefits (such as retirement, life insurance, medical insurance, or the use of a PHA vehicle) are not. The term **salary **includes: The term **bonus **refers to: If a PHA has a FY rather than a calendar year end, the PHA must calculate the impacted payments for the calendar year. [**Download HUD-Form 52725**](https://www.bdo.com/getmedia/2c7f2234-433c-4ad2-89d5-04a39558b860/52725.xlsx) ### Contact Us   *Copyright © 2026 BDO USA, P.C. All rights reserved.www.bdo.com* Tags: [State & Local Government](https://blog.becpas.com/tag/state-local-government) [Back to Blog](https://blog.becpas.com) ## Related Articles ## [Just Ask Why: The Key to Successful Audit Remediation](https://blog.becpas.com/just-ask-why-the-key-to-successful-audit-remediation) Just Ask Why: The Key to Successful Audit Remediation [Read More ](https://blog.becpas.com/just-ask-why-the-key-to-successful-audit-remediation) ## [Name, Image, Likeness: Income Tax Considerations For Student-Athletes](https://blog.becpas.com/name-image-likeness-income-tax-considerations-for-student-athletes) Student-athletes can now enter into name, image and likeness (NIL) contracts for compensation. NIL... 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