We are writing to remind you of important amendments to New Jersey’s Multiple Dwelling Reporting Rule (“MDRR”) issued by the Division on Civil Rights (“DCR”), which significantly expands reporting obligations for many property owners and managers.
Key Changes You Should Know:
1. Expanded Applicability. The MDRR now applies to owners or managers who own or manage 25 or more rental units in total statewide, regardless of type (apartments, duplexes, townhomes, single family homes, condominiums) and regardless of whether those units are located in a single building or across multiple properties, so long as they are under one management company or have ownership in common.
2. New Data Collection Requirements. Beginning January 1, 2026, MDRR reporting will require the collection of additional information for applicants, tenants, and occupants, including gender, familial status and receipt of rental assistance. A new DCR Tenant/Applicant Inquiry Form must be used for this purpose starting January 1, 2026. Click HERE for the form. (The form is also available on the DCR’s website). This form is effective January 1, 2026, for reports to be filed January 30, 2027.
3. Collecting the information. Owners are required to provide the updated Tenant/Applicant Inquiry Form to tenants/leaseholders beginning January 1, 2026. Tenants/leaseholders will complete the form on behalf of all occupants in their dwelling unit. If a tenant/leaseholder does not complete or return the form, owners must report for each known occupant in the dwelling unit to the best of their knowledge and indicate that they completed the form on behalf of the tenant/leaseholder. Owners must not, however, enter a dwelling unit without the permission of a tenant/leaseholder or occupant, or otherwise conduct an investigation for the purpose of collecting information related to the MDRR.
Importantly:
- Housing providers may not require applicants, tenants, or occupants to complete the form.
- However, housing providers are still required to report the information to the best of their knowledge, even if the form is not completed. While optional for tenants, compliance is mandatory for housing providers.
Important Filing Deadlines:
- January 30, 2026: MDRR filing is still required, but this filing will be based on 2025 data and the preamendment rules and form.
- January 30, 2027, and thereafter: Reports must comply with the new MDRR amendments, using data collected with the new form beginning January 1, 2026.
Ongoing Owner Obligations:
- Owners must provide the MDRR form to applicants and tenants:
- upon completion of the initial application process, before criminal background screening;
- at the start of the lease;
- with every lease renewal offer; or
- once per year, if the lease term is one year or less.
Leases, lease renewals, and application materials should be updated accordingly.
The DCR issued FAQs, which can be found HERE
Increased penalties for Late Filing:
The DCR has also increased penalties for late MDRR filings:
- 15–30 days late: $500
- 31–60 days late: $1,000
- 61–90 days late: $1,500
- More than 90 days late: $2,500
If you have questions about how these changes affect your properties, or would like assistance with updating your forms or compliance procedures, please contact us.
This information is provided solely for information purposes. It should not be construed as legal advice on any specific matter and is not intended to create an attorney-client relationship. The information provided herein may not be applicable to all situations and should not be acted upon without specific legal advice based upon particular circumstances. Each legal matter is unique, and prior results do not guarantee a similar outcome.