Multifamily Middle Market Tax Exemption

Multifamily Middle Market Tax Exemption is sponsored by Florida Housing Finance Corporation. Provides tax exemptions to expand affordable housing opportunities without using Florida Housing funds.

Nelson Mullins - 2026 Missing Middle Tax Exemption: Are You Ready?

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By Hollie A. Croft , Nicholas W. Heckman , Daniel Helligar It’s that time of year again to start preparing to apply for Florida’s Multifamily Middle Market (also known as “Missing Middle”) property tax exemption.

As a refresher, the Missing Middle property tax exemption provides qualifying multifamily developments a discount equal to either (i) 75% of the assessed value of the units that provide affordable housing to persons and families with annual household incomes between 81% and 120% of the area median income (AMI), or (ii) 100% of the assessed value of the units that provide affordable housing to persons and families with annual household incomes at or below 80% AMI.

The exemption requires a development to be “newly constructed” within the past five years before the date of the project owner’s first filing for the Florida Housing Finance Corporation’s (“Florida Housing”) Multifamily Middle Market (“MMM”) Certificate.

To be eligible for the Missing Middle property tax exemption, the development must contain at least 71 units for tenants with incomes no greater than 120% AMI.

For a specific unit to qualify, the unit must provide housing to tenants meeting such income restriction and the gross rent must not exceed the lesser of the amount published by Florida Housing on its multifamily rental programs rent and income limit chart, or 90% of the fair market value rent as determined by a rental market study, which must be provided with the certification request.

Interested owners should be aware of the following key deadlines when pursuing the 2026 Missing Middle property tax exemption: FHFC confirmed in its Sept. 16th workshop that its MMM Certification portal will open on Oct. 1, 2025 and will begin accepting requests on Jan.

1, 2026. Owners must submit their requests to Florida Housing no later than Jan. 15, 2026, by 3 p.

m. EST; Owners must provide the affordable housing by Jan. 1, 2026; Owners do not need to reconfirm the filed MMM Certification once the MMM Certification is filed with FHFC; Florida Housing will provide MMM Certification Notices to owners and local property appraisers by Feb.

15, 2026; and If an owner receives an MMM Certification Notice, it must also apply for the Missing Middle property tax exemption by March 1, 2026 by submitting the MMM Certification Notice, the exemption application (DR-504AFH), and any other required documentation to their local property appraiser.

Interested owners should be aware that the MMM Certification Notice from Florida Housing is not a final determination of the ad valorem tax exemption. Whether the Missing Middle property tax exemption is ultimately granted to such project owner is at the purview of the local property appraiser.

Moreover, simply because you received the Missing Middle property tax exemption in 2025 does not mean you automatically receive the exemption in 2026. A project owner that received the Missing Middle property tax exemption in 2025 must file and apply annually for the MMM Certification Notice with Florida Housing and the Missing Middle property tax exemption application with the applicable county property appraiser’s office.

If you have any questions about the Missing Middle property tax exemption, including how to accurately complete Florida Housing’s MMM Certification Notice and file the Missing Middle property tax exemption application with your local property appraiser’s office, please get in touch with your Nelson Mullins contact.

Affordable and Workforce Housing Please keep in mind that merely contacting Nelson Mullins Riley & Scarborough LLP will not establish an attorney-client relationship. Nelson Mullins cannot represent you until the firm knows there would not be a conflict of interest, and the firm determines that it is otherwise able to accept the engagement.

Accordingly, please do not send Nelson Mullins any information or documents until a formal attorney-client relationship has been established through an interview with an attorney and authorized in the form of an engagement letter from Nelson Mullins. Any information or documents sent prior to your receipt of an engagement letter cannot be treated as confidences, secrets or protected information of any nature.

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