VA Appraisal Requirements in 2026: Process, Report, Alternative Valuations, and Bias Oversight

The VA appraisal is structurally different from a conventional or FHA appraisal, and treating it as if it were the same is the source of most preventable VA appraisal delays. The order does not go to a lender-rotation panel; it goes through WebLGY to a VA fee-panel appraiser. The market value answer is not the only thing being evaluated; the appraiser is also screening the property against VA's Minimum Property Requirements (MPRs). And when the file moves into review, it does not move through the lender's underwriting team alone; it passes through a Staff Appraisal Reviewer (SAR) and culminates in a Notice of Value (NOV) issued to the veteran.

This guide walks through the appraisal lifecycle as it actually runs in 2026, with citations to the regulation, the active VA Loan Guaranty Circulars, and the relevant chapters of VA Pamphlet 26-7.

Who orders the appraisal and how?

Per VA Pamphlet 26-7 Chapter 10, Topic 2 (Ordering an Appraisal), authorized requesters order VA appraisals through WebLGY, accessed via the VA Information Portal at vip.vba.va.gov. A Certificate of Eligibility (COE) request must already be in flight before the appraisal can be ordered. In most cases, VA automatically assigns an appraiser from VA's fee-panel to perform the appraisal; the lender does not select the appraiser.

The mechanical steps:

1. The requester logs into WebLGY and submits the appraisal order.
2. VA assigns a fee-panel appraiser, generally automatically.
3. The requester uploads the executed sales contract (and, for new construction, the construction exhibits) into WebLGY the same day the appraisal is requested.
4. The requester certifies, at the time of order, that the appraisal fee will be forwarded to the appraiser upon receipt of the Notice of Value.

A common preventable delay: ordering the appraisal before the sales contract is uploaded. Per Ch 10, Topic 3, if the sales contract has not been uploaded by the time the appraiser begins work, the appraiser must place the assignment on hold and notify the requester, with the delay logged in WebLGY notes.

What is the SAR and where does the NOV come from?

The Staff Appraisal Reviewer (SAR) is a lender or servicer employee who has been authorized by VA to review completed appraisals on behalf of VA. Per Ch 10, Topic 1 (Appraisal Process Summary), the completed appraisal report is uploaded into WebLGY, electronically scored by VA's Appraisal Management System (AMS), then reviewed by either a SAR or by VA staff directly. The reviewer issues the Notice of Value (NOV) to the veteran.

The NOV is the operative document for the appraisal phase. It tells the veteran the appraised value, lists any MPR repairs the appraiser flagged, and contains the recommendation that the veteran consider obtaining a home inspection in addition to the VA appraisal.

The Lender Appraisal Processing Program (LAPP) authorizes lender-employed SARs to issue NOVs on the lender's own loans without VA staff in the loop, which is the workflow most retail and broker shops operate under. LAPP and the SAR designation are governed by Pamphlet 26-7 Chapter 15.

What forms does the appraisal report use?

Per Ch 11, Topic 3 (Appraisal Report Contents), VA accepts a specific list of Fannie Mae appraisal forms:

• Form 1004 (Uniform Residential Appraisal Report) for the standard interior fee-panel appraisal
• Form 2055 (Exterior-Only Inspection Residential Appraisal Report), permitted for liquidation appraisals when interior access was not provided, and as the supplemental form for certain alternative valuations under Circular 26-22-13
• Form 1004C (Manufactured Home Appraisal Report)
• Form 1073 (Individual Condominium Unit Appraisal Report)
• Form 1075 (Exterior-Only Inspection Individual Condominium Unit Appraisal Report) for liquidation appraisals
• Form 1025 (Small Residential Income Property Appraisal Report)

The report itself must list the lender's name and "Department of Veterans Affairs" in the Lender/Client field, and the assigned fee appraiser's signature and VA ID must appear in the signature block.

What are the alternative valuation methods?

For most of the program's history, the default was an interior fee-panel appraisal on every transaction. VA Loan Guaranty Circular 26-22-13 (July 28, 2022): Procedures for Alternative Valuation Methods changed that, authorizing three alternatives under specific conditions:

• Exterior-Only Appraisals, where the appraiser views only the exterior of the property and uses Form 2055 with required photographs of all sides plus detailed exterior notes, and addresses any visible MPRs the exterior view reveals.
• Desktop Appraisals, where the appraiser does not view the property in person and instead relies on data sources, listings, MLS records, and tax records, with the supplemental information set defined in Exhibit B.
• Hybrid valuation processes via the Assisted Appraisal Processing Program (AAPP), where the appraiser works from information gathered by another party (typically a property data collector) under a contractual arrangement.

Exhibit A to Circular 26-22-13 carries the Appraisal Assignment Waterfall, which maps mortgage purpose (Purchase, IRRRL, Cash-out Refinance) crossed with down-payment percentage to acceptable appraisal types. The waterfall determines which methods are eligible for a given transaction; an interior fee-panel appraisal is always acceptable, but the alternatives are scoped to specific cells. Exhibit B carries the supplemental information requirements that attach to each alternative.

The alternatives supplement rather than replace the framework in Pamphlet 26-7 Chapter 11. When the alternative-valuation Circular and the Handbook differ on procedural detail for the same transaction type, the Circular's specific guidance for the alternative is the operative answer for that alternative; the Handbook controls the underlying framework.

What changed for Connecticut on January 1, 2026?

VA Loan Guaranty Circular 26-25-11 (December 31, 2025): Adoption of Planning Regions in Connecticut changed the geographic basis VA uses to assign appraisers in Connecticut. The state requested in 2022 that nine Planning Regions be adopted as county-equivalents in place of Connecticut's eight historical counties. After FHFA recognized the Planning Regions for conforming loan limit purposes effective January 1, 2026, VA followed.

For appraisal ordering, the operational impact is straightforward:

• Appraisal requests for properties in Connecticut must use the appropriate Planning Region in the county field in WebLGY, not the historical county name.
• Appraisers approved for VA assignments in Connecticut had their GEO locations updated to reflect the new Planning Regions, and are expected to cover the entire region regardless of size.
• Failing to select the correct Planning Region in WebLGY may delay appraisal assignment and completion.

This is a Connecticut-only change, but it is one of the most-likely preventable delays for any broker doing volume in the state.

What is VA doing about appraisal bias?

VA Loan Guaranty Circular 26-23-5 (January 18, 2023): Oversight of Appraisal Reports to Promote Fair Housing for All Veterans announced enhanced oversight procedures for detecting discriminatory bias in VA appraisal reports. The Circular came out of the federal Property Appraisal and Valuation Equity (PAVE) Task Force initiative.

The protected categories under the enhanced oversight: race, color, national origin, religion, sex (including gender identity and sexual orientation), age, familial status, and disability.

The operational pieces brokers and SARs should know:

• VA reviews submitted appraisal reports for indicators of potential bias. Reports flagged on initial review are escalated to a deeper review.
• If an escalated review confirms bias, the appraiser is subject to removal from the VA-approved fee panel, and VA refers the case to the appropriate enforcement agencies.
• The Circular reminds appraisers of the certifications they sign on the Fannie Mae Form 1004 URAR (specifically Appraiser Certification 17), which prohibits basing the analysis on race, color, religion, sex, national origin, age, familial status, handicap, or disability.
• Lender-approved SARs who identify potential bias in a report under review are expected to escalate immediately rather than issuing the NOV as if the bias were absent.
• VA recommends bias, fair housing, and fair lending training for all fee-panel appraisers and lender-approved SARs.

This Circular is the Circulars-side anchor for appraisal-bias compliance in VA loans. The regulatory backbone for property valuation and the conditions for guaranty sit at 38 CFR §§ 36.4254 and 36.4302.

What does the appraiser inspect for MPRs?

Pamphlet 26-7 Chapter 12 carries the full Minimum Property Requirements list. Brokers should treat the Topic list as the operational checklist when reviewing a file before ordering the appraisal. The high-frequency MPR catches include:

• Topic 4: Access requirements (private road maintenance agreements, RLC approval where the veteran is accepting a disproportionate share)
• Topic 8: Special Flood Hazard Area (SFHA flood insurance required; properties in SFHAs without available flood insurance are ineligible)
• Topic 14: Utilities (electricity for lighting; the appraiser does not perform operational checks)
• Topic 15-19: Water supply and sanitary facilities, including individual water supply, individual sewage disposal, shared wells, and community systems
• Topic 23: Heating (must heat all habitable areas to a minimum temperature; oil heat, wood-burning, and other non-standard sources have specific requirements)
• Topic 26: Roof covering (remaining service life)
• Topic 30: Swimming pools (must be properly secured)
• Topic 32: Lead-based paint (all defective paint surfaces on a residential property built before 1978 must be stabilized; per VA funding fee in 2026, the PAINT-related issue framework is consistent across the FHA and VA programs in spirit but distinct in specifics)
• Topic 33: Wood Destroying Insects/Fungus/Dry Rot (the WDO inspection-fee allocation question is governed by Circular 26-22-11 and Change 1; FHA brokers will recognize the parallel to the FHA pest inspection workflow)

When the appraiser flags an MPR repair, the appraisal is prepared "subject to" the completion of the repair. The repair must be completed and verified before the loan can be guaranteed by VA, although Chapter 12 Topic 43 allows lender-held escrow for post-closing repair completion under specified conditions.

We will cover the May 1, 2026 Pamphlet 26-7 Chapter 12 changes in the next post in this series.

Reconsideration of value, repair inspections, and lender changes

Three operational pieces from Chapter 10 deserve attention because they are the most frequent post-NOV friction points:

• Reconsideration of Value (Topic 22). When the value comes in below contract or the veteran disputes the valuation, the ROV process allows the lender to submit additional comparable sales and supporting analysis. The ROV does not start the appraisal over; it asks the original appraiser (and, if escalated, VA staff) to reconsider in light of the additional data.
• Repair Inspections (Topic 23). When MPR repairs are required, a repair inspection (typically by the original appraiser) is needed before the NOV can be cleared for closing. The repair inspection fee is separate from the appraisal fee and is also collected through the WebLGY workflow.
• Request from the Veteran to Change Lenders (Topic 26). When a veteran moves the loan to a different lender mid-process, the appraisal generally moves with the file. The new lender takes over the WebLGY assignment and the existing NOV (where one has been issued) generally remains valid.

Common pitfalls

Five patterns generate the most VA appraisal delays:

1. Ordering the appraisal before the sales contract is uploaded. Per Ch 10 Topic 3, the appraiser must place the assignment on hold until the contract arrives. Same-day upload prevents the delay.
2. Selecting the wrong Connecticut Planning Region. Per Circular 26-25-11, Connecticut transitioned from counties to Planning Regions effective January 1, 2026. Selecting the historical county name in WebLGY may delay appraiser assignment.
3. Assuming the alternative-valuation methods apply to every transaction. Per Circular 26-22-13 Exhibit A, the waterfall maps mortgage purpose and down payment to eligible appraisal types. Ordering a Desktop where the waterfall calls for Interior is a re-assignment.
4. Issuing an NOV with potential bias indicators that the SAR overlooked. Per Circular 26-23-5, lender-approved SARs are expected to escalate flagged reports rather than push them through. The downside risk on a bias miss is appraiser panel removal and enforcement referral.
5. Treating MPR repairs as recommendations rather than conditions. The appraisal is prepared "subject to" MPR repairs. The loan cannot be guaranteed by VA until those repairs are completed, with the narrow Topic 43 exception for lender-escrowed post-closing completion.

For more agency guideline breakdowns, see the Agency Guidelines series. Related guides: VA loan assumption process in 2026, VA funding fee in 2026, FHA appraisal requirements.

This article is for informational purposes only and is not professional advice. Always verify against 38 CFR Part 36, the active VA Loan Guaranty Circulars 26-22-13 (and Exhibits A and B), 26-23-5, 26-25-11, and the relevant chapters of VA Pamphlet 26-7 (especially Chapters 10, 11, 12, and 15) before making decisions on a specific appraisal file.