Counting of Units
By December 31, 2026 jurisdictions must be able to show the combined number of newly constructed affordable housing units and existing units converted to affordable housing within its territorial boundaries has increased by their committed amount (3%, 6%, or 9%) over their submitted baseline of affordable housing units.
The unit count must be completed by December 31, 2026 in order to remain eligible for the next three (3) year cycle of Proposition 123 funds starting in 2027.
If a local government does not meet its commitment to increase affordable housing by the end of the 3-year funding cycle, they will be ineligible to receive Proposition 123 funding during the first year of the next 3-year cycle.
Portal for Unit Count Submissions
Portal for Regional Collaboration
Optional DOH Unit Count Spreadsheet Template - Be sure to download or make a copy of the file first.
Proposition 123 Submission Package Checklist
Demonstrating Compliance with the Unit Count
At the end of each three-year commitment cycle, local and tribal governments must submit information demonstrating that they have met their affordable housing commitments.
Supporting material must be filed through DOH’s submission portal by December 31st of the final year of each commitment cycle (identified below).
- December 31, 2026
- December 31, 2029
Jurisdictions are encouraged, but not required to submit documentation as soon as they are ready to count units toward their commitment. The portal is set up so multiple forms over a period of time can be submitted as needed. The portal and relevant forms will be available from March 15, 2025 to December 31, 2026.
There are three qualifying affordable housing categories under Proposition 123. Select a category to learn more.
Naturally Occurring Affordable Housing (NOAH)
DOH has provided a Unit Counting Spreadsheet template for your use as needed. The spreadsheet is intended to be uploaded in the portal under the section titled “Using DOH Provided Template.” This is in lieu of completing the separate submission forms through the portal.
Using the Submission Portal
The DOH Unit Count Submission Portal is for submitting documentation to prove compliance with a local government’s Proposition 123 commitment. The following table outlines the form options.
For detailed information on documentation, please refer to the Proposition 123 Submission Package Checklist.
| Form Options | Category Description | Key Required Documentation |
|---|---|---|
| New Construction with affordability mechanism | New units permitted after commitment date with an Affordability Mechanism. | Permit for vertical construction, Affordability Mechanism documentation, income verification process, project details (address, type, AMI levels). |
| Preservation with affordability mechanism | Existing at-risk affordable housing secured with an Affordability Mechanism (e.g., through renewal, acquisition, or rehab). | Affordability Mechanism documentation, evidence of preservation activity/scope of work, applicable financial closing or permit documentation. |
| Conversion with affordability mechanism | Market-rate or non-residential units newly designated as affordable with an Affordability Mechanism. | Affordability Mechanism documentation, documentation of previous/current use, applicable financial closing or permit documentation. |
| Down Payment Assistance (DPA) | Units supported by a DPA program that are a new addition to the housing stock. | Proof of DPA (e.g., promissory note), unit spreadsheet with loan amount, sale price, closing date, # of bedrooms, and household AMI. |
| Naturally Occurring Affordable Housing (NOAH) | Housing that is naturally affordable without a formal Affordability Mechanism (new, preserved, or converted after commitment filing). | Confirmation of no Affordability Mechanism and new addition to housing stock. Unit-level data (address, price/rent, date) must be uploaded, or project-specific form completed. |
| Using DOH Provided Template | You can use the optional DOH Unit Counting Spreadsheet and upload it to the portal instead of completing the separate forms. | Documentation will still need to be provided based on unit category. |
Documentation: Jurisdictions are welcome to upload documentation in whatever format is easiest. This can include a zip file, shared file links, or uploading documents separately. If using shared file links, please ensure dola_prop123support@state.co.us has view access permissions.