For the entire 50-year history of the federal manufactured housing program, the code governing these homes has required each one to be built on a permanent chassis. Congress took that requirement out this year, and on Oct. 7, 2026 the Department of Housing and Urban Development published the Next Generation Manufactured Housing Action Plan, a seven-part roadmap for what the program becomes without it β including a proposal to write a federal construction code for apartment buildings of five units or more.
That last item is the most consequential for anyone building housing at scale. The plan proposes a performance-based construction and safety code modeled on 24 CFR Part 3280, the Manufactured Home Construction and Safety Standards, covering residential structures with five or more dwelling units. HUD notes that larger buildings raise questions the current standards do not fully address β common corridors, stairs, accessibility, fire separation, shared systems and egress β and says extending the code to them “could create a national pathway for repeatable multifamily construction under a consistent federal regulatory framework.”
The reason that phrase matters is federal preemption. HUD-code homes are built to a single national standard that overrides state and local building codes, which is why a manufactured home can be shipped and sited across state lines without a local code review of its construction. No equivalent federal pathway exists for a five-story apartment building.
What the ROAD to Housing Act set in motion
The trigger is the 21st Century ROAD to Housing Act. Section 301 removes the permanent chassis requirement and directs HUD, in consultation with the Manufactured Housing Consensus Committee, to establish revised standards for homes built without one. The statute separately requires HUD to update manufactured housing energy efficiency standards.
“For 50 years, the HUD Code has provided a national framework for safe, quality, affordable housing,” Secretary Scott Turner said in the announcement. “Now, HUD is building on that foundation to expand innovation in design and construction for the next generation of manufactured homes to unleash the American Dream for even more families.”
Joe Gormley, who oversees the Office of Housing and the Federal Housing Administration, put the engineering consequence more plainly. “Removing the permanent chassis requirement is more than a technical change,” he said. “It creates an opportunity to reconsider how manufactured homes are designed, transported, assembled, and regulated, so we can increase supply for first-time homebuyers.”
The seven workstreams
The plan lists them in order: update the energy efficiency standards; update Part 3280 for chassis-free construction; update 24 CFR Part 3285, the Model Manufactured Home Installation Standards, for foundations and installation; establish a multi-module construction pathway; develop the performance-based code for buildings with five or more units; publish chassis-free case studies; and create an on-ramp for manufacturers already building modular and other off-site housing to enter the HUD regulatory system.
Several have concrete starting points. On the energy standards, the plan says the consensus committee reaffirmed its 2022 recommendations at its July 23, 2026 meeting, and that the Office of Manufactured Housing Programs will conduct rulemaking to update Part 3280 consistent with them, with HUD’s Office of Policy Development and Research providing technical and analytical support for the required Regulatory Impact Analysis.
The chassis-free rulemaking would address structural design, transportation, lifting and connections. The installation rewrite would cover foundations, anchoring, structural connections and setting procedures. The multi-module pathway would be explored under 24 CFR Part 3282, the procedural and enforcement regulations, to give builders more freedom in how sections are designed, transported, combined and completed on site “while preserving substantial factory completion” β the condition that keeps a home inside the federal program rather than under local codes.
The case-study workstream is aimed at the non-engineering obstacles: HUD says it will document early chassis-free projects and publish information on zoning, appraisal, lending, insurance and market acceptance. Those are the practical barriers agents and lenders encounter, and they are not solved by a code change.
A roadmap, not a rule
HUD is explicit about the plan’s status. “The intent is not to predetermine individual regulatory outcomes,” it says; the document identifies where standards, research, demonstrations, technical analysis and stakeholder input are likely to be needed. Every substantive change still runs through notice-and-comment rulemaking and the consensus committee, which means years rather than months.
One piece is already moving. On June 12, 2026, HUD published a proposed rule in the Federal Register revising the definition of a manufactured home so that upper-floor sections could be transported and built without a permanent chassis, a change aimed at multi-story manufactured housing.
The policy push is running alongside state-level activity on the same idea β Maryland ordered a modular housing push and created a permitting acceleration team earlier this year β and alongside real demand: in Altadena, Calif., wildfire victims turned to factory-built homes to speed rebuilding. On our reading, the five-or-more-units code is the item to watch, because it is the only one that would open a new product line rather than modernize an existing one. More policy coverage is in Housing Market.
