A proposed Virginia rule would double manager licence fees and add a bond
A proposed Virginia rule would double manager licence fees and add a bond
2026-09-19 · Virginia · Regulation · Pending — not yet law
Virginia's proposed rewrite of its community association manager regulations would double the licence fee, double the licence term, require a fidelity bond and prohibit a manager from taking undisclosed money from vendors. The proposed action on 18VAC48-50 was published in the Virginia Register of Regulations on September 22, 2025, with a public hearing on October 14 and a comment period that closed November 21, 2025.1
It is proposed, not final. Nothing in it binds anyone yet.
What the Board says it is doing
The Register's summary describes the package: “The proposed amendments include (i) adding a new definition and revising some existing definitions; (ii) clarifying the requirement for common interest community manager firms to be licensed…(iii) requiring completion of a board-approved training module…(iv) extending the period of licensure for common interest community managers to two years and the period for reinstatement of a license or certificate to one year…”
The fee and term changes
The initial application fee and the renewal fee for a common interest community manager would each rise from $100 to $200. Principal and supervisory employee fees would stay at $75 for both application and renewal.
Against that, the licence term would extend from one year to two, and the reinstatement window from six months to a year. On a per-year basis the fee is therefore roughly unchanged; what changes is the cash timing and the length of the grace period for a lapsed licence.
The fidelity bond, and how it is sized
A new section, 18VAC48-50-33, would require a fidelity bond sized to the money the manager actually handles: coverage equal to the lesser of $2 million or the highest aggregate operating and reserve balance the firm held in the prior fiscal year, subject to a minimum of $10,000.
The logic of a floating cap is straightforward. A firm managing a handful of small Virginia communities holds a different amount of other people's money than one managing fifty, and a flat bond would be simultaneously punitive for the first and useless for the second.
This is the control that speaks most directly to the receivership record. Two Virginia management companies were placed into court-appointed receivership in the Ombudsman's latest reporting year, and the Common Interest Community Management Recovery Fund exists because association money sometimes does not survive a manager's failure.
Three new standards of conduct
18VAC48-50-195 would impose management-contract requirements — what a contract between a Virginia association and its manager must contain. That pairs with the statutory right in § 55.1-1837, in force since July 1, 2025, to terminate an auto-renewing contract on 60 days' notice without cause or penalty.
18VAC48-50-205 would bar a manager from receiving undisclosed remuneration from a vendor without board authorisation. The practice it targets is familiar: a manager steering an association's landscaping, insurance or roofing work to a vendor who pays a referral fee the board never sees.
18VAC48-50-225 would create a duty to the public, including a duty to report other licensees' violations. That is a significant step. A reporting obligation turns every licensed Virginia manager into part of the enforcement mechanism.
Licensees would also have to report changes — firm name, address, principals, loss of a professional designation — within 30 days.
The requirement the Board removed from its own proposal
At its August 28, 2025 meeting the Board voted unanimously to strike two proposed sections, 18VAC48-50-95.C.9 and 18VAC48-50-256.9, which would have imposed a training requirement. The recorded reason was that “no evidence had been provided to the Governor showing that harm would occur without the training requirement”, invoking Executive Order 19's mandate for a 25 percent reduction in discretionary regulatory requirements.2
That is worth stating plainly because it cuts against the direction of the rest of the package. A Virginia regulator proposed a training requirement for the people who manage other people's homes and money, and removed it because it could not evidence the harm of going without.
Who this reaches, and who it does not
The regulations govern licensed common interest community managers. Section 54.1-2347 exempts an association's own employees managing that association's community, uncompensated residents, and uncompensated board members. A self-managed Virginia association is outside the entire licensing regime — and 89 of the 310 complaints in the Ombudsman's latest reporting year concerned self-managed communities.
The conditions that change the answer
Proposed is not final. The comment period closed November 21, 2025; a final action would publish separately in the Register with its own effective date.
Text can change between stages. The training-requirement removal is the proof.
Fees here are manager fees. Association registration fees sit in 18VAC48-60 and changed effective December 31, 2025.
What to watch next
The final action on 18VAC48-50. Two of the Board's three regulatory chapters completed final action in 2025 — the Ombudsman regulations on August 1 and the registration regulations on December 31. The manager regulations are the outstanding one.
Related Virginia HOA Topics
- 18VAC48-50, Common Interest Community Manager Regulations, proposed action — Virginia Register of Regulations, Vol. 42, Iss. 3 (Sept. 22, 2025) ↩
- Common Interest Community Board, meeting minutes, August 28, 2025 (draft) — Virginia Regulatory Town Hall ↩
- Va. Code § 54.1-2347, Exceptions and exemptions generally — Code of Virginia ↩
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