The U.S. Department of Agriculture has set states a firm November 1, 2025 deadline to implement far-reaching changes to the Supplemental Nutrition Assistance Program (SNAP) that will sharply boost work requirements for millions of Americans. The reforms, mandated by the One Big Beautiful Bill Act enacted into law in July 2025, are the most sweeping update to food aid eligibility in decades and could affect as many as 42 million SNAP beneficiaries nationwide.
November 1 implementation deadline
The USDA’s Food and Nutrition Service sent a comprehensive memo to all state agencies on October 3, 2025, requiring the implementation of new work requirements for able-bodied adults without dependents (ABAWDs) starting November 1. The expedited time frame gives states with less than four weeks to retool their SNAP administration systems, training for staff, and inform affected recipients of the sweeping change in their benefits eligibility.
States are now mandated to screen all new applicants and current renewals of SNAP benefits under the new regulations, while clearly documenting the changes in writing as well as verbally to ensure that households understand who must work or participate in training programs in order to continue qualifying. The accelerated implementation timeline has also sparked criticism from advocates of food aid who maintain that the unreasonably short deadline could result in administrative chaos and unintended benefit losses.
Higher age requirements impact more adults
The most significant change raises the age range of ABAWD work requirements from the previous 18-54 years to now covering adults through age 64. This raise puts an automatic extra 10 years’ worth of adult beneficiaries under the rigid three-month time limit except if they meet specific work standards. Adults in the expanded age group must currently work or participate in approved activities for at least 80 hours a month to be eligible for SNAP benefits after the initial three months within a three-year period.
Adults aged 55 to 64 were previously considered approaching elderly status under SNAP policy and were largely exempt from work requirements. Only those above the age of 65 still automatically qualify for exemption under the new law.
Tougher rules for parents and caregivers
The bill significantly withdraws parents’ and caregivers’ exemptions by updating dependency requirements. Adults providing care to any minor under 18 years old earlier enjoyed blanket exemptions from ABAWD work requirements. On November 1, this exemption is provided to parents or guardians with minors under 14 years of age.
This change guarantees parents of teenagers between the ages of 14 and 17 years now have the same work requirements as unmarried adults, forcing them to meet the 80-hour work requirement monthly or risk losing their benefits after three months. This is an extremely brutal stroke to single parents who may struggle to balance teenage caring responsibilities with meeting work requirements.
Removal of central exemptions
The One Big Beautiful Bill Act cancels some exemptions that were newly added to protect vulnerable populations. On November 1, three groups will lose their protected status and must now be subject to regular ABAWD work requirements:
- Veterans who previously were automatically exempted in honor of their service will now face the same work demands as other able-bodied adults.
- Homeless persons, although offering great barriers to gainful employment, are no longer automatically exempt.
- Young adults aged 18 to 24 who aged out of foster care, a group that has been documented as offering great challenges to age out successfully into adulthood, will lose protected status under the new policy.
Such disenrollments are a significant policy shift from recognizing the unique challenges these populations face in meeting traditional work requirements.
Understanding the three-month time limit
ABAWDs who cannot meet work requirements face stern sanctions under federal law. They are limited to receiving SNAP benefits for a paltry three months in any three-year period unless they work 20 hours a week, participate in qualifying education or training activities for 80 hours a month, or volunteer with qualifying organizations. After they exhaust their three-month allowance, they are excluded from receiving benefits until they satisfy the work requirement or until three years have elapsed.
This time limit puts a particular burden on individuals in communities with low job opportunities, poor public transport, or for which employment barriers include low education, criminal records, or unnoticed health issues.
Limited State flexibility under new waiver rules
The legislation strictly prohibits states from exercising their power to waive work mandates in weaker economic areas. States previously had been able to request waivers for areas with insufficient employment or economically distressed areas. The new rules allow waivers only when the unemployment rate is more than 10 percent, making it virtually impossible for most areas to receive relief.
Alaska and Hawaii receive special dispensation, allowed to seek a waiver if their unemployment rates are 150 percent of the country’s average, and the two states are allowed to temporarily exempt individuals if they demonstrate good faith effort application. The new law also limits place-based waivers to one year, from the previous three-year limit.
Read more: Who gets SNAP Payments this week in Texas?
