How the OBBBA / HR1 (P.L. 119-21) work-requirement expansion rolled out, state by state, July 2025 -> December 2026. One chip per state per lane; click any chip for full detail + public sources. Grounded in 7 CFR 273.24, FNS OBBBA memos, state agency directives, and court records via /snap-oracle; every record adversarially re-verified. General information, not legal advice.
The one rule: an ABAWD can receive SNAP for only 3 countable months in a 36-month period without meeting an 80-hours/month work requirement (or an exemption/waiver). OBBBA made far more people ABAWDs (age -> 64; veteran/homeless/former-foster exemptions removed; young-child exemption -> under 14) and narrowed the waivers states can use. The lanes below trace, per state: waiver ends -> prep -> clock starts -> people lose benefits.
Chip flags: P = partial / area-waiver (only part of the state enforces) · ~ = phased in renewal-by-renewal · X = waiver/terminations affected by court action. ‹ / › = event sits just before/after the window.
Federal milestones
National rule dates that apply to every state - the baseline the states react to.
Waiver ends
The one date a state's ABAWD waiver actually ended (only states that had one). Attempted-but-court-blocked early terminations are NOT shown here.
Enforcement begins (first countable month)
The first month that counts toward a person's 3-month allowance. All 53 jurisdictions appear here. (An FNS memo of Nov 13, 2025 instructed states to assign no countable month for November 2025 - many states still paid full November benefits - so counting resumed December 2025, the first countable month for most states. This is a national counting instruction, not benefit proration.)
First terminations / exhaustion (newly-subject HR1 cohort)
When the first NEWLY-SUBJECT (HR1) cohort actually loses SNAP - first countable month + 3 countable months. People already subject to the time limit before HR1 could be removed earlier and throughout the series as ordinary pre-HR1 churn; this lane marks the expansion's human-impact date.
Litigation / court actions
Court actions that moved the dates - markers, not a per-state row.
36-month clock boundaries (in-window)
Only states whose 36-month window opens, closes, or resets inside Jul 2025-Dec 2026 (when a window resets, everyone in that state gets a fresh 3 months).
Reading the 36-month clock lane. States choose how to measure the 36 months: most use a fixed statewide clock (one window that resets the whole state at once); several use an individual per-person clock (CT, HI, KY, MS, NH, OK, TX), one state's methodology isn't published (DE), and one state's window is unconfirmed (NV). This lane shows only the windows that open, close, or reset inside the timeline: opens - Kansas (Oct 2025), Vermont (Nov 2025), California & Minnesota (Jan 2026), Louisiana (Apr 2026), DC (Jun 2026); closes/resets - New Mexico (May), Colorado/Maryland/Missouri (Jun), Rhode Island (Aug), Maine/New York/Nevada (Sep), Georgia/Iowa/South Dakota (Nov), Illinois/Massachusetts/Washington (Dec 2026). Louisiana closes Mar 31 2026 and reopens Apr 1 - a statewide reset.
The litigation, in one line. USDA tried to end ~18 statewide "insufficient jobs" waivers ~Nov 2 2025. A single case - Rhode Island State Council of Churches v. Rollins (D.R.I.) - blocked that nationwide on Oct 31, so the court-affected waivers ran to their original expirations (IL/NJ/NV/WA = Jan 31 2026; NY = Feb 28 2026) and USDA reinstated them Feb 26 2026 (uniform protective endpoint Apr 30 2026). California's statewide waiver was court-preserved to its original Jan 31 2026 expiration (Appendix A), with enforcement deferred to Jun 1 2026 regardless. There was no separate AG-coalition or Tribal ABAWD suit and no distinct "April 30" ruling. The case ended by joint stipulated dismissal Mar 2 2026 (no ruling on the merits).
Built from the snap-oracle corpus + live primary-source verification (FNS waiver letters, state SNAP manuals/directives, court records), with every per-state record adversarially re-verified on 2026-06-27 and again on 2026-08-26 (53-jurisdiction sweep + adjudication). All sources are public primary sources. Enforcement & first-termination lanes cover all 50 states + DC + Guam + USVI. First-termination months are projections except where a state has confirmed them (shown in each chip's detail).