Starting November 1, 2025, the United States Department of Agriculture (USDA) will begin full nationwide enforcement of updated work rules under the Supplemental Nutrition Assistance Program (SNAP) for able-bodied adults without dependents (ABAWDs).
These changes strengthen the requirement that recipients must work, train, or engage in authorised activities for at least 80 hours per month in order to continue receiving food assistance.
The launch of this rule marks the closure of the transition phase and the tightening of state-level waivers and exemptions across all U.S. states.
Nationwide Enforcement Begins
The USDA’s Food and Nutrition Service (FNS) has declared that from November 1 2025 onward, every state must apply the updated SNAP work-requirement rules to ABAWDs.
Under this framework, individuals who don’t meet the monthly 80-hour participation threshold may face loss of benefits after three months in any 36-month period.
Previously, many states used geographic waivers or extended exemptions to reduce the number of individuals subject to these rules; with the new directive, those broad area-based waivers are being phased out.
What Exactly Is Changing
At the heart of the policy is the ABAWD time-limit rule: food assistance is limited to three months in a 36-month window unless the recipient:
- works or participates in an approved activity for at least 80 hours per month, or
- qualifies for an approved exemption or a verified good-cause deferral.
The USDA’s updated guidance instructs states to:
- track and verify monthly work or training hours,
- apply exemptions consistently, and
- submit compliance data to FNS.
Under the new rule, the flexibility states previously enjoyed to grant broad waivers is significantly reduced, resulting in a standardised national policy across all states.
Who Is Affected and Who Is Exempt
The rule targets able-bodied adults aged 18–64 without dependent children. Those in this group who fail to meet the 80-hour monthly requirement risk loss of SNAP benefits after three months of eligibility within a 36-month span.
Exemptions include:
- pregnant individuals,
- those medically certified as unable to work,
- primary caregivers of dependent children, and
- persons with documented good-cause reasons (for example: illness, emergency situation or homelessness).
States also retain limited discretionary exemptions for special cases.
Waivers, Exemptions and State Readiness
Although federal law still allows area waivers, the USDA’s new framework makes them more difficult to obtain. States must now show data-driven criteria—such as unusually high unemployment rates or a lack of job opportunities—to qualify for temporary area exemptions.
A USDA memo emphasises that all states must:
- submit plans that outline how they will implement the ABAWD time-limit fully,
- document the systems used for compliance tracking, and
- restrict overuse of waivers that previously shielded broad regions from enforcement.
In practice, this means national uniform enforcement, although there may still be limited localised waivers and individual exemptions.
Implementation Timeline and Technical Details
| Component | Requirement / Deadline |
|---|---|
| Work Hours Requirement | 80 hours/month (employment, job-training, verified volunteering, or combination) |
| Time Limit Rule | 3 months of SNAP in any 36-month period unless participation or exemption applies |
| Exemption Tracking | States must verify and document exemptions with evidence |
| Quality Control Reviews | A “hold harmless” period ends; state errors will count toward federal audits |
| Full Enforcement Date | November 1, 2025 |
By the rollout date, all states must ensure their eligibility systems, notifications and documentation align fully with the updated USDA guidelines.
Funding and Operational Challenges
As states gear up for implementation in November, several have warned of potential SNAP payment delays if a federal funding lapse persists.
States such as Pennsylvania have publicly flagged that November benefits might be delayed or disrupted without timely congressional approval of funding.
Although this funding issue is separate from the new work-requirement policy, it could still impact benefit rollout and payment scheduling for millions of recipients.
What SNAP Households Should Do
For those subject to the ABAWD rule, it is crucial to document compliance with the 80-hour requirement each month. Qualifying activities include:
- paid employment,
- job training or work-fare programmes, and
- verified community service.
Households should contact their SNAP caseworker to:
- confirm participation,
- request an exemption review, or
- submit proof of qualifying activities.
If there are barriers—such as health issues, caregiving responsibilities or unstable schedules—it’s important to apply for a good-cause deferral promptly.
What States Must Prepare
States are required to update their eligibility systems to:
- identify and track ABAWD cases,
- record participation hours each month,
- manage exemption records and notifications, and
- generate compliance reports for USDA’s Quality Control review.
The temporary “hold harmless” policy that protected states from penalties during the transition ends in November 2025; from then on, states will be held accountable for any misapplication of the ABAWD rules in federal reviews.
Policy Debate and Broader Implications
Proponents argue that enforcing stricter work requirements will encourage workforce participation and reduce long-term dependency on federal aid, while ensuring SNAP resources reach those most in need.
Critics, however, caution that the policy may cause increased food insecurity for adults facing barriers such as mental-health conditions, lack of transportation or unstable work patterns. They emphasise that administrative delays or limited job-training opportunities could unfairly penalise eligible individuals.
The ultimate success of the policy will depend on state capacity, outreach, and whether realistic employment pathways exist for low‐income adults.
Starting November 1 2025, the USDA’s updated SNAP work requirement rules for ABAWDs will be enforced uniformly across all states. Individuals must meet or document 80 hours of qualifying work or training each month—or qualify for an exemption—to maintain benefit eligibility under the three-month time-limit rule.
States must have systems in place for tracking, verification and reporting; meanwhile, households should act proactively to understand the new rules, document their participation and apply for exemptions or deferrals where appropriate.
With potential funding challenges on the horizon, staying informed and prepared will be key for both beneficiaries and state agencies.
FAQs
Who exactly is subject to this new SNAP rule?
The rule applies to able-bodied adults aged 18–64 who do not have dependent children. These individuals must meet the 80-hour/month participation requirement or qualify for an exemption to continue receiving SNAP benefits.
What counts toward the 80-hour monthly requirement?
Qualifying activities include paid work, job training programmes, verified community service or any approved activity that is tracked and documented by the state. A combination of activities is also permitted as long as the monthly total reaches 80 hours.
What if I can’t meet the 80-hour requirement due to illness or caregiving?
If you fall under an exemption such as being medically unable to work, pregnant, a primary caregiver of children, or you have a good-cause reason (e.g., emergency or homelessness), you may be exempt or eligible for a deferral. Contact your caseworker to apply for an exemption or document your good‐cause.