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Two Rhode Island deadlines land on September 30

Two Rhode Island deadlines land on September 30
Rhode Island · Compliance

Two Rhode Island deadlines land on September 30

Two dates that matter to Rhode Island associations fall on the same day, two weeks from now, and neither is resolved.

One: the flood programme

The National Flood Insurance Program's authority to write and renew flood insurance contracts expires September 30, 2026. Congress must act again by then or the authority lapses.

This is not hypothetical. The NFIP already lapsed at the start of the federal shutdown on October 1, 2025, during which no new or renewed policies could be sold. It was reauthorised in the legislation that ended the shutdown, extended first to January 30, 2026 and then to September 30, 2026, with the reauthorisation applied retroactively to October 1, 2025.1

What a lapse does and does not do is worth stating carefully, because it is widely misunderstood. Policies already in force continue to the end of their existing term. What stops is the writing of new and renewed contracts. For a Rhode Island condominium association that is a closing problem and a renewal problem rather than an immediate coverage problem — but in a state where a substantial share of the condominium stock sits in a mapped flood zone, a closing problem in October is a real one.

Two: the short-term rental commission

Rhode Island's House special legislative commission on short-term rental policy was reinstated by Resolution 98 of 2026 (H 7301, enacted February 11, 2026). The resolution revived the commission created by House Resolution 422 of 2023, reappointed the same members, and authorised it

to continue its study and make a report to the House of Representatives on or before September 30, 2026, and said commission shall expire on January 10, 2027.2

It is chaired by Representative Lauren Carson of Newport. In a January 2026 interview she said the commission “will be gearing up for the new year”, beginning by “evaluating the impact the 2025 Summer season had on communities and various proposals from several communities around the state.3

This column could find no public evidence — no agenda, no minutes, no meeting notice, no news coverage — that the commission has convened in 2026, and no signal of what it will recommend. That is a gap in the public record rather than a finding that it has not met. Fifteen days from the reporting deadline, it is the most reportable thing about it.

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Why the commission has been waiting, and what it was waiting for

The chair has explained the delay in her own words. In a May 2025 op-ed she wrote that the commission was holding off on recommending legislation until pending Superior Court challenges to municipal short-term rental ordinances — in Newport, Narragansett and Exeter — were resolved. She also described what the commission had heard in its earlier life: testimony from more than two hundred residents, municipal officials, tourism representatives and property owners, on the inconsistency between the state registry and seventeen separate municipal registration systems, on platform tax-remittance transparency, and on fire and building code compliance.

One of those cases has been decided. Hughes v. Town of Exeter Zoning Board of Review, WC-2024-0058, decided January 6, 2025, upheld Exeter's special-use-permit requirement for short-term rentals against a state-law preemption argument.4 Another has not resolved so cleanly: Narragansett's ordinance has been under a preliminary injunction since October 2024, the town suspended registration in January 2025, and as of a December 2025 council session it was considering scrapping the freestanding article and rebuilding the rules inside its zoning ordinance.

What is at stake for a covenant community either way

The patchwork is the problem the commission was created to address, and it is the patchwork an association has to operate inside today.

The state definition is thirty nights. Section 42-63.1-14: “not to exceed thirty (30) nights at a time.” Registration with the Department of Business Regulation is required for any short-term rental listed on a third-party hosting platform doing business in Rhode Island, annually, before the listing goes up.

The municipal definitions are shorter and they differ. Narragansett prohibits stays of fewer than seven nights. Newport regulates short-term rentals as a zoning use called “guest facilities”, defined by reference to periods of twenty-nine consecutive days or less, with owner-or-manager residence required where the use needs a special permit and a cap of five sleeping rooms and two guests per room. South Kingstown uses “less than thirty (30) consecutive days”, with a $100 annual registration and a maximum fine of $300.

None of them displaces a covenant. Narragansett says so expressly, requiring the applicant to certify that the permit “shall not operate to allow any residential property owner to violate any private conditions, covenants, and restrictions”. Our Rhode Island short-term rentals page covers what an association's own restriction can do.

A statewide minimum-stay rule, if the commission recommended one and the legislature adopted it, would be the first thing in years to change that arithmetic — and depending on how it was drafted, it could either reinforce an association's restriction or preempt it. Both are live possibilities and neither is on the record yet.

And a third date, for shoreline communities

January 1, 2027. P.L. 2026, ch. 165 adds two shoreline access disclosures — § 34-18-20(e) for tenancies and § 42-63.1-14(l) for short-term rentals — each requiring the owner to give the renter the statutory recital that the public may use the shore “up to ten feet (10') landward of the recognizable high tide line”. The short-term rental version can be discharged by displaying the disclosure conspicuously in the platform listing before booking.

What a board can do in the next two weeks

On flood: find out when your policy renews. If the renewal date falls in October or November, ask your agent now what happens on a lapse and whether the renewal can be bound before September 30. If any unit in the building is under agreement, the closing date is the number that matters.

On flood: know what the RCBAP does not cover. The Residential Condominium Building Association Policy is the association's flood policy, and its coinsurance and per-unit limit mechanics decide how much of a loss actually gets paid. This column did not verify the current figures from FEMA's own manual and is not going to quote numbers it has not read — ask your agent for the specific coinsurance percentage and per-unit building limit on your policy, in writing.

On short-term rentals: do not wait for the commission. If your community's restriction needs updating, the mortgagee-consent obstacle that used to block declaration amendments was removed in June 2025, and the municipal landscape is unsettled enough that borrowing a town's definition into your own document is a bad idea.

On both: check the commission's own page in early October. A report filed with the House on or before September 30 becomes a public document, and it is the best single indication of where Rhode Island short-term rental law is going in the January 2027 session.

What to watch next

Whether the report is filed at all. The commission expires January 10, 2027, and its predecessor resolutions were extended repeatedly — the 2023 original was extended in 2024 and again in 2026, each time with the previous reporting date rescinded. Another extension resolution in early 2027 would be the most likely outcome if the pending litigation is still unresolved.

Related Rhode Island HOA Topics

← All Rhode Island HOA Topics

  1. National Association of Realtors, “FAQ: National Flood Insurance Program expires September 30, 2026” — on the lapse, reauthorization and current expiry
  2. Resolution 98 (2026 – H 7301), enacted February 11, 2026 — reinstating the House short-term rental commission, report due September 30, 2026
  3. What'sUpNewp, “Legislative Outlook: Carson sees healthcare and housing as critical issues” (January 2026)
  4. Hughes v. Town of Exeter Zoning Board of Review, WC-2024-0058 (R.I. Super. Jan. 6, 2025) — decision

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