Summary 

• SNAP eligibility updates effective November 1, 2025, could directly affect how employers qualify for the Work Opportunity Tax Credit (WOTC).
  
• Historically, over 60% of all WOTC certifications come from the SNAP target group.
  
• WOTC is set to expire December 31, 2025, unless renewed by Congress.
  
• Employers should prepare for potential program lapses and understand how changes may impact credit eligibility.
  

What’s Changing and Why It Matters

The Supplemental Nutrition Assistance Program (SNAP) is updating its work requirements for adults without dependents starting November 1, 2025. These new rules could reduce the number of individuals who qualify for benefits, and, by extension, who qualify employers for the Work Opportunity Tax Credit (WOTC).

The WOTC rewards employers for hiring individuals who face barriers to employment, including SNAP recipients. From 2020–2024, more than 60% of all WOTC certifications came from this group, making SNAP changes especially impactful for employers.

How WOTC Works and What’s at Risk

The Work Opportunity Tax Credit was established in 1996 under the Small Business Job Protection Act to encourage inclusive hiring. Since then, it’s been renewed multiple times and occasionally lapsed due to legislative delays.

Here’s how it works:

1. Employers hire eligible individuals from target groups such as veterans, long-term unemployed, or SNAP recipients.
   
2. Employers submit certifications to their state workforce agency within 28 days of the hire.
   
3. Certified employers receive tax credits based on wages paid to qualifying employees.
   

However, because the program is statutory, it depends on Congressional reauthorization. The WOTC is currently scheduled to expire on December 31, 2025, and has experienced six lapses since 1998, creating “hiatus” periods where submissions are accepted but certifications are paused.

Recent SNAP Changes and Their WOTC Impact

The most significant SNAP adjustment centers on work-hour requirements for adults without dependents. These updates could limit SNAP eligibility and reduce the number of employees who qualify under the WOTC’s SNAP Target Group.

According to FY 2024 data, 68% of all WOTC certifications were linked to SNAP recipients, showing how deeply these two programs are connected. Employers may see fewer qualifying candidates if eligibility is tightened.

To learn more about how WOTC certification works, visit McMillian & Associates’ WOTC Program page or review guidance from the U.S. Department of Labor’s WOTC overview. 

How Employers Can Prepare

Here’s what employers can do before the end of 2025:

1. Review your hiring process: Confirm your WOTC submission workflow is timely and compliant.
   
2. Monitor SNAP eligibility changes: Track state-level updates after Nov. 1 that could affect applicant status.
   
3. Plan for a possible WOTC hiatus: If the program lapses after Dec. 31, you can still submit applications, but certifications will pause until renewal.
   
4. Stay connected with experts: Work with your WOTC consultant or contact McMillian & Associates for program updates and impact analysis.

Key Takeaways

• SNAP changes effective November 1, 2025, may reduce WOTC-eligible hires.
  
• WOTC expires December 31, 2025, and could face another hiatus before reauthorization.
  
• Employers should stay proactive: continue submitting applications, track eligibility updates, and lean on trusted WOTC experts for guidance.
  

Stay Tuned

This article kicks off our 90-Day WOTC Watch Series, tracking how the first 30 days of SNAP changes affect WOTC activity and whether Congress moves to extend the credit into 2026.

Stay connected with us on LinkedIn or reach out to David McMillian at dmcmillian@mcataxcredits.com for more insights.

For real-world examples of how McMillian & Associates helps employers capture WOTC credits, explore our Success Stories.