SNAP rule changes: who is affected, and when

The 2025 budget law, Public Law 119-21, rewrote several parts of the Food and Nutrition Act in eight sections numbered 10101 to 10108. Four of them change who can get SNAP or how long they can keep it; the rest change what the states pay. This page follows the statute and the two implementation memos the Food and Nutrition Service sent to state agencies on September 4 and October 31, 2025.

The time limit, and who it now reaches

SNAP has long had a rule for adults without dependents: under section 6(o) of the Act, an adult who is not working or in a work program for at least 80 hours a month can receive benefits for only three months in a 36-month period. Section 10102 of the new law changes the exceptions, which is where the reach of the rule is decided.

The upper age moved from 54 to 64. FNS's implementation memo states it directly: individuals aged 18 to 64 are now subject to the time limit unless they meet another exception. The memo also draws a line that is easy to miss. The general work requirement, a separate rule, still ends at 60, and people 60 and older are still "elderly" for every other SNAP purpose, including the medical deduction and the uncapped shelter deduction.

The exception for a parent or other household member responsible for a dependent child now applies only where the child is under 14. Before the law, it was under 18. An adult whose youngest child is 14 to 17 is subject to the time limit unless something else exempts them.

Three exceptions written into the 2023 debt-ceiling law were removed: for veterans, for people experiencing homelessness, and for people 24 or younger who were in foster care at 18. The memo says those individuals are once again subject to the time limit, as they were before 2023.

One set of exceptions was added, for members of Indian tribes, urban Indians and California Indians as defined in the Indian Health Care Improvement Act. The exceptions that remain are those in the statute: under 18 or over 65, medically certified as unfit for work, pregnant, or exempt from the general work requirement.

Waivers

Section 10102 also narrows the geographic waivers that let a state suspend the time limit where jobs are scarce. The memo summarizes the change: states other than Alaska and Hawaii may now request a waiver only for an area where the unemployment rate is 10 percent or higher, and the old ground of "not enough jobs" is gone. Alaska and Hawaii can qualify when their rate reaches 1.5 times the national rate, and can ask for a temporary exemption, expiring no later than December 31, 2028, while they show a good-faith effort to comply.

Non-citizens

Section 10108 replaces section 6(f) of the Act with a closed list. A person who is not a citizen or national can take part in SNAP only if they are a lawful permanent resident, a Cuban or Haitian entrant, or a person lawfully living in the United States under a Compact of Free Association. The October 31 memo says it plainly: groups that qualified before under the 1996 welfare law and are not on that list are no longer eligible.

The statute also says how the household is treated afterwards. The income and resources of the person made ineligible still count in deciding the rest of the household's eligibility and benefit, less a pro rata share if the state chooses. The person leaves the case; the money they bring in does not.

When the states had to act

Both memos use the same formula. The work-rule and non-citizen provisions were effective upon enactment, July 4, 2025. States must apply the new criteria to new applicants at initial certification and to households already receiving SNAP at recertification, after screening. FNS allowed a 120-day quality-control grace period for errors in applying section 10108, ending November 1, 2025, which is the practical date by which every state was expected to be applying the non-citizen rule.

For a household, that means the change arrives with the next recertification, and the notice the state sends is the document to read.

The money behind it

Two provisions shift costs to the states, and they explain much of the pressure on state agencies to move quickly.

Section 10106 cuts the federal share of state administrative costs from 50 percent to 25 percent beginning in fiscal 2027, which starts on October 1, 2026.

Section 10105 makes states pay part of the benefits themselves from fiscal 2028, on a sliding scale set by each state's payment error rate. A rate under 6 percent keeps the federal share at 100 percent. From 6 to under 8 percent the state pays 5 percent of benefit costs; from 8 to under 10 percent, 10 percent; at 10 percent or more, 15 percent. For fiscal 2028 a state may choose its 2025 or 2026 error rate; from fiscal 2029 the rate from three years earlier is used. A state whose error rate, multiplied by 1.5, was 20 percent or more in 2025 starts a year later, and one that hits that mark in 2026 starts in fiscal 2030.

The smaller changes

Section 10101 fixes the Thrifty Food Plan, the basis of the maximum benefit, to the 2021 report with annual inflation adjustments and allows no re-evaluation before October 1, 2027. Section 10103 limits the link between energy assistance and the standard utility allowance to households with an elderly or disabled member. Section 10104 stops internet costs from counting toward the shelter deduction. Section 10107 ends mandatory funding for SNAP nutrition education after the 2025 grant year.

What to do

A person aged 55 to 64 without a child under 14 at home should expect the time limit at the next recertification and ask the state agency what counts toward the 80 hours; work, a job-training program and, in many states, volunteering all can. The medical exception is unchanged, and a doctor's certification of unfitness for work still lifts the limit. Households with a non-citizen member should compare that member's status with the four groups above before the recertification interview, because the decision is made there. The SNAP eligibility and payment dates explainer covers the income limits and the state issuance schedules, which the law did not change, and the income limits tracker carries the fiscal 2027 figures.