Per USDA Food and Nutrition Service implementation guidance, the changes to the Supplemental Nutrition Assistance Program's work requirements under the July 2025 reconciliation law took effect Nov. 1, 2025, and states were required to apply them to cases processed on or after that date. The law raised the upper age of the able-bodied-adult work requirement from 54 to 64 and narrowed several exemption categories that previously shielded parents, veterans, and others. By mid-March 2026, states are in their first full season of operating under the new rules, and county offices and advocacy groups report a mixed picture of implementation.
What changed?
The core rule is unchanged: adults deemed able to work must show at least 80 hours of work or qualifying activity per month, or a combination, to receive SNAP for more than three months in a three-year period. What the 2025 law changed is who is subject to that test. The age range now runs through age 64 rather than 54. It also narrowed the exemptions for veterans, people experiencing homelessness, and former foster youth, and it limited the ability of parents of older teens to claim an exemption, per USDA guidance and CRS analysis of the law's SNAP provisions.
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Who is affected?
Adults ages 55 through 64 who previously aged out of the requirement are newly covered, as are people in the narrowed exemption groups. USDA's implementation memoranda, including guidance on ABAWD exceptions issued through the fall of 2025, direct state agencies on how to screen for exemptions and how to apply the new time-limit rules to cases reopened or recertified after Nov. 1. States with waivers covering labor-surplus areas must also reconcile those waivers with the new statutory limits.
What it means for you
If you receive SNAP and are between 55 and 64, or if you relied on one of the narrowed exemptions, your caseworker may now ask for work hours or training participation at your next recertification. The exemptions you qualify for, and the documentation each state accepts, are set out in your state agency's notices, which USDA requires states to publish. Check your state SNAP agency's website or your client notice for the specifics that apply to your case, and contact your local office before a recertification deadline rather than after, because time-limit clocking can start with a missed notice.
What happens next?
The reconciliation law also shifts a share of SNAP benefit and administrative costs to states starting later in the decade, depending on error rates, which will interact with the new work requirements as states budget for fiscal 2027. USDA continues to issue supplemental guidance on exceptions, waivered areas, and data reporting. For the near term, the practical benchmark is case processing: benefit offices are applying the new screening rules case by case, and the first substantial caseload data under the Nov. 1 change is expected in USDA's fiscal 2026 reports.