Program election (9% vs. 4% vs. hybrid) — Wisconsin

Two QAPs, both currently in force, depending which door you walk through

WHEDA runs its Housing Tax Credit program on a two-year QAP cycle, and as of this research two consecutive QAPs are simultaneously operative. The 2025-2026 QAP's competitive round (9% Credit + State HTC) already closed and was awarded — WHEDA's own 2026 Program page reports 62 Project Concepts submitted, 53 advancing past Concept Determination, 49 reaching Full Application, and 35 developments ultimately awarded $47.8 million in competitive credits across 2,128 units in 26 communities and 15 counties (28 new construction, 7 rehabilitation/adaptive reuse; 24 family developments, the remainder senior) — but that same 2025-2026 QAP still governs the Noncompetitive 4% Credit cycle, which opened June 17, 2026 and runs on a rolling basis through October 31, 2026. As of a September 17, 2026 status update on WHEDA's own site, that cycle had committed $35,031,371 of bond volume cap against $151,917,252.40 still available, with 13 applications submitted (2 awarded, 6 under review, 5 ineligible or withdrawn).

Meanwhile, the 2027-2028 QAP is already the operative plan for anyone starting a new competitive-cycle deal today: its Project Concept Submission deadline is November 2, 2026, well before this research was conducted, and WHEDA's live 2027 Program page describes the program as "actively recruiting applications." The document itself carries a Governor's cover letter dated June 15, 2026 ("Every two years, we roll up our sleeves and assess what is needed and possible to create a Qualified Allocation Plan... The 2027-2028 QAP reflects our evolving understanding of Wisconsin's dynamic housing, demographic, and development climate"), and the file WHEDA currently serves at its permanent QAP URL — confirmed by direct download and file-type verification, distinct from an earlier public-comment "final draft" copy that circulated under a similar filename — is dated "Revised June 2026" on its own cover page. This research could not locate the specific WHEDA Board of Directors vote date that preceded the Governor's approval; the QAP states the Plan is implemented "following a public hearing, approval of the Plan by the WHEDA Board of Directors, and final approval of the Plan by the Governor," but only the Governor's June 15, 2026 letter and WHEDA's June 16, 2026 public announcement were confirmed directly.

Competitive vs. Noncompetitive: the actual mechanics of each track

The 2027-2028 QAP states plainly: "WHEDA will allocate the 9% Federal Credit and State of Wisconsin Housing Tax Credit in a single annual competitive application cycle and referred to collectively as the Competitive Credits." A developer may receive up to two Competitive Credit awards per year in any combination of 9% or State HTC, and WHEDA will treat affiliated developers, co-developers, or consultants as a single developer if a structure looks designed to circumvent that limit. The maximum 9% Credit WHEDA will allocate to any one project is $1.4 million; the maximum State Credit is also $1.4 million. No more than 15% of Competitive Credits may go to rehabilitation of existing rental housing unless WHEDA receives an insufficient number of eligible new-construction applications, and county caps apply: no more than two 9% awards and one State award in any Metro county, or one 9% and one State award in any Non-Metro county (Tribal-owned projects are exempt from the county caps). All developments must score at least 65 points to be eligible for an award, per Appendix C — a threshold WHEDA reserves the right to change.

Set-asides are purely geographic, not the multi-tier system some other states run: 45% of Competitive Credits go to a defined "Metro" set-aside (Brown, Dane, Kenosha, Milwaukee, Racine, and Waukesha counties) and 55% to "Non-Metro" (every other county), with WHEDA free to shift 9% credits between the two set-asides to fund the last application in a cycle. A separate 2027 Innovative Set-Aside reserves $2.4 million of the 9% Credit for one Metro and one Non-Metro project that demonstrate innovative cost-reduction methods, calculated outside the geographic set-asides and exempt from the county caps. One provision reads ambiguously and is worth flagging rather than resolving by assumption: the QAP requires WHEDA to make adjustments "to ensure at least 10% of the 9% Credit being awarded to projects: [i] involving qualified nonprofit organizations, and [ii] that rehabilitate existing rental housing" — the text does not make clear whether this is one combined 10% floor covering both categories together, or two separate 10% floors. IRC Section 42(h)(5) independently requires at least 10% of a state's 9% ceiling go to qualified nonprofit-involved projects as a matter of federal law regardless of how WHEDA resolves the QAP's own phrasing.

The Noncompetitive track is a genuinely different animal: "WHEDA will accept applications for TE Bonds after the conclusion of the competitive HTC application cycle and following WHEDA's announcement of volume cap availability... on a rolling basis until the TE Bonds have been exhausted or until the conclusion of the cycle on October 31." There is no scoring competition against other applicants for the 4% Credit itself — an application that clears WHEDA's threshold requirements and minimum score, and secures bond volume cap, gets a Reservation roughly 30 days after a complete Initial Application. The real constraint on this track isn't a point score, it's whether tax-exempt bond volume cap is still available when a developer applies.

The Wisconsin Housing Tax Credit: a real state credit, and the actual hybrid pathway

Wisconsin's state credit is codified at Wis. Stat. § 234.45, created by 2017 Wisconsin Act 176 as a nonrefundable income and franchise tax credit that WHEDA certifies to a person with an ownership interest in a qualified federal Section 42 development financed with tax-exempt bonds. The current annual aggregate cap is $42,000,000, covering all amounts every certificate-holder is eligible to claim in every year of the credit period, plus unallocated credit carried forward from prior years. A 2025 amendment (2025 Wisconsin Act 236, adding Wis. Stat. § 234.45(5m)) now requires that, in every QAP WHEDA adopts after April 10, 2026, at least 35% of the value of all state tax credits allocated each year go to qualified developments in rural areas — and the 2027-2028 QAP is the first plan bound by that mandate, which is exactly where its stated preference for properties in a city, town, or village of 150,000 or fewer people, and its goal of directing at least 35% of state credits to places under 10,000 people (at least 10 miles from any city of 50,000 or more), actually comes from.

The real hybrid question in Wisconsin isn't a 9%/4% blend on a single project the way some states occasionally structure one — this QAP contains no provision for pairing the two federal credit types on the same deal. The actual hybrid choice is which federal credit the State HTC rides alongside, and the two paths are priced and timed differently. In the Competitive cycle, the State HTC is awarded alongside the 9% Credit as part of the same scored application and is capped at the time of Reservation. In the Noncompetitive cycle, the QAP states directly: "The State of Wisconsin Housing Tax Credit must be paired with the Federal 4% Credit," WHEDA "will cap the State Credit allocation at the time of Reservation but the Federal 4% Credit may float until issuance of Form(s) 8609," and — critically for a developer choosing this path — "WHEDA will prioritize TE Bonds for projects using the State Credit," meaning a request for State HTC on top of a 4% deal earns priority queue position for scarce bond volume cap. Appendix D sets the State Credit's own applicable percentage rate by geography rather than mirroring the federal 4% rate outright: Metro set-aside deals size their state credit at a 4% rate, while Non-Metro deals size theirs at a much richer 10% rate — a direct, quantified subsidy tilt toward rural development layered on top of the statutory 35% allocation floor.

Historical award data confirms the State HTC actually pairs with both federal credit types in practice, not just on paper: WHEDA's 2023 awards paired $7.9 million in state credits with 10 developments in the same cycle that funded 13 developments with federal 9% credit, which is consistent with the Competitive-cycle pairing this QAP describes rather than a purely 4%-only design left over from the credit's 2017 origins.

The federal bond test: WHEDA names the 25% figure, then caps volume cap tighter than either federal number

Unlike QAPs that incorporate the federal aggregate-basis test purely by reference, Wisconsin's plan states the new post-OBBBA figure explicitly. The 2025-2026 QAP's Noncompetitive section reads: "Code requires that for projects using the 4% Credit and bonds issued after December 31, 2025, 25% or more of the aggregate basis of building(s) and land must be financed with Tax-Exempt bonds" — a direct restatement of 26 U.S.C. § 42(h)(4)(B) as amended by the One Big Beautiful Bill Act (Pub. L. 119-21, § 70422(b)(1)), which added that 25% alternative test alongside the longstanding 50% test. The 2027-2028 QAP's own Noncompetitive section doesn't repeat the percentage by name but does reference it directly when describing post-Reservation bond increases: any increase in Tax-Exempt Bond volume after initial Reservation is capped at 15%, "with such increases only permitted to ensure projects will meet the 25% test."

Naming the federal floor didn't stop WHEDA from imposing its own tighter administrative ceiling on new bond volume cap per project. The 2027-2028 QAP limits new Tax-Exempt Bond volume cap to "the higher of: 1. 30% of the property's expected Aggregate Basis or 2. Permanent supportable debt, not to exceed 55%" — leaving roughly five percentage points of cushion above the new 25% federal floor, a far tighter margin than the gap between the old 50% test and a 30% administrative cap would have implied. That single unified figure is itself the product of a 2025-to-2026 phase-in this research was able to trace directly: the 2025-2026 QAP originally ran a bifurcated cap for its 2025 cycle — projects using WHEDA's own tax-exempt bond financing were capped at the higher of 35% of aggregate basis or permanent supportable debt plus 5% (not to exceed 60%), while projects using conduit or local bond issuance were capped at the higher of 30% or permanent supportable debt (not to exceed 55%) — before that same QAP collapsed both categories into the single 30%/55% figure for its 2026 cycle, a number the 2027-2028 QAP carries forward unchanged. For any bond amount requested above the 30% aggregate-basis line, WHEDA states it "may substitute refunding Tax-Exempt bonds for new volume cap" rather than granting additional new volume cap outright.