The LIHTC Cost Certification Timeline & Checklist

August 28, 2025

The LIHTC cost certification is the final cost audit that supports IRS Form 8609 issuance. Do it right, and investor equity and credits flow on time. Do it late—or incorrectly—and the project can stall right when it needs momentum.


Milestones to watch

  • Construction completion and punch list
  • Final draw and retainage release
  • As-built budgets and change orders
  • Placed-in-service dates by building
  • Final sources and uses


Documents to assemble early
Contracts and all amendments, pay apps and change orders, lien waivers, architect/engineering invoices, permit/impact fees, developer fee schedule and payments, land/closing files and other permanent documents, loan statements or history, draw schedules, and settlement statements. Organize by cost code or draw, and keep track related-party transactions.


State agency nuances
Louisiana, Mississippi, Arkansas, Alabama, Tennessee, Oklahoma, and Texas each have checklists and formats. Expect different eligible basis treatments, developer fee and contractor limit caps, and documentation preferences. Start with the strictest checklist so one binder works everywhere.


How to speed acceptance
Reconcile construction draws to the GL; tie contracts to change orders; separate soft costs consistently; document developer fee calculations; and make it easy for reviewers to verify totals. Coordinate timing with lenders and investors so 8609s can be requested as soon as reports are issued.


Closing out construction soon? Line up your audit now so equity and credits land when you need them.