TOPA (Updated for the 2025 RENTAL Act)

As of December 31, 2025, DC's TOPA requirements changed significantly for many 2-4 unit rental properties. Qualifying properties are generally exempt from TOPA purchase rights and no longer require an Offer of Sale. Instead, owners must follow a simplified notice process.

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What Changed?

For most qualifying 2-4 unit buildings:

  • No tenant purchase rights
  • No Offer of Sale requirement
  • No assignment rights
  • No negotiation period
  • No tenant response required
  • Owners must instead comply with the Notice of Potential Sale requirements.

Notice of Potential Sale

Owners must:

  • Deliver a Notice of Potential Sale within 3 calendar days of receiving or soliciting an offer 
  • Use approved delivery methods 
  • Provide required documentation to DHCD 
  • Deliver notice to DHCD and OTA


For qualifying2-4 unitbuildings, this is the primary compliance requirement.

Common Owner Mistakes

  • Assuming exemption means no compliance requirements 
  • Missing notice deadlines 
  • Improper delivery methods 
  • Incomplete supporting documentation 

How UMA Helps

  • Confirm exemption eligibility 
  • Prepare compliant notice packages 
  • Coordinate required filings 
  • Reduce compliance risk and delays 

Owner Outcome

A streamlined sale process withsubstantially fewerprocedural burdens than pre-2025 TOPA.

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