Single Audit Threshold: Fiscal-Year Checklist

The single audit threshold is $1,000,000 in federal awards expended for fiscal years beginning on or after October 1, 2024. For fiscal years beginning before that date, the applicable threshold is $750,000. The date your organization received a grant, the amount deposited in its bank account, and the date its audit is submitted do not replace that fiscal-year test. Federal Audit Clearinghouse threshold guidance

For a nonprofit preparing or correcting financial records on October 26, 2026, the transition still matters. Current-year planning and a late submission for an older year may involve different thresholds. This guide focuses on making that determination, documenting the federal expenditure population, and organizing submission responsibilities. It does not announce a new 2026 threshold change.

Apply the single audit threshold to the right fiscal year

Begin with your organization’s actual fiscal-year start date. Do not assume a calendar year, use the federal government’s fiscal year automatically, or select a threshold based only on the year printed on an audit report.

The Federal Audit Clearinghouse explicitly distinguishes fiscal years starting before October 1, 2024 from those starting on or after that date. The revised regulatory text requires an audit when federal awards expended reach or exceed $1,000,000, with a single audit generally required unless a permissible program-specific election applies. FAC threshold guidance; 2 CFR 200.501

Fiscal year	Start-date position	Applicable expenditure threshold
July 1, 2024–June 30, 2025	Before October 1, 2024	$750,000
October 1, 2024–September 30, 2025	On the transition date	$1,000,000
January 1–December 31, 2025	After the transition date	$1,000,000
July 1, 2025–June 30, 2026	After the transition date	$1,000,000

These examples demonstrate the date rule; they are not an extension of any filing deadline. Exactly $1,000,000 meets the revised threshold. A total just below it requires careful reconciliation, not rounding to the nearest thousand dollars.

Keep the threshold decision in the audit planning file with the fiscal-year dates, source citation, expenditure schedule, and reviewer approval. If prior-year reports used an incorrect threshold, consult the auditor and appropriate federal oversight or cognizant agency about the necessary response rather than silently changing a worksheet.

Separate audit applicability from award-term applicability

Two different transition questions often get combined. The audit threshold is determined using the fiscal-year guidance above. Administrative requirements and cost principles for a particular award depend on the governing award terms and the agency’s implementation of the 2024 revisions.

OMB’s final guidance became effective October 1, 2024 and permitted, but did not require, agencies to apply the revisions to awards issued earlier. An older grant’s cost rules therefore do not independently determine the threshold for the organization’s current audit year. Conversely, a new grant award does not retroactively raise the threshold for an older fiscal year. OMB final guidance, effective-date statement

Use separate columns in your grant register for the award’s governing terms and the organization’s audit-year determination. This modest separation prevents an award-level amendment from being mistaken for an organization-level audit exemption.

Determine expenditures, not merely receipts

The regulation measures federal awards expended. A large award authorization can span several years, and an advance cash deposit can arrive before the related activity. Neither number is automatically the federal expenditure total for the audit period.

The schedule of expenditures of federal awards, commonly called the SEFA, must cover the same period as the financial statements and include federal expenditures determined under 2 CFR 200.502. Loan and loan-guarantee programs can require special calculations; the FAC specifically directs readers to that section for loans. Do not apply a simple cash-expense formula to every assistance type. 2 CFR 200.510(b); FAC threshold guidance

Federal expenditures as a recipient and as a subrecipient are generally within the audit population. Payments the organization receives for goods or services as a contractor under a federal award are treated differently under Subpart F. Establish the substance of each relationship instead of assuming that every government-funded payment is a subaward. 2 CFR 200.501(g)

A state or county funding agreement may contain both federal and nonfederal funding. Request the Assistance Listing number, federal award identification, and federal portion from the pass-through entity when they are unclear. Do not count the entire agreement as federal merely because the payer is a government body, and do not omit it merely because the payment did not come directly from Washington.

Hypothetical example: two different conclusions

Assume a nonprofit uses a July–June fiscal year and has $890,000 in properly determined federal expenditures for July 1, 2024 through June 30, 2025. That year began before October 1, 2024, so the $750,000 threshold applies. The organization is above the applicable threshold even if the audit is completed during 2026.

Now assume the same nonprofit has $890,000 in federal expenditures for July 1, 2025 through June 30, 2026. That year began after the transition date, so the $1,000,000 threshold applies. It is below the Subpart F threshold for that year, subject to the exceptions described in the regulation. These are hypothetical facts, not findings about a real organization. 2 CFR 200.501(e)

Suppose the second year’s $890,000 estimate excludes $160,000 of federal pass-through expenditures that were mistakenly coded as a state-only grant. After correction, the total becomes $1,050,000. The revised threshold is exceeded. This is why the completeness of the award inventory matters more than whether one direct federal grant is individually large.

Treat changes in the forecast as planning signals. A forecast below the threshold is not a final exemption determination. Continue reconciling through year-end and inspect late invoices, payroll adjustments, corrections, and applicable noncash assistance before concluding.

Build a SEFA-ready reconciliation

Even when an audit is not expected, a recommended internal federal expenditure schedule helps finance staff monitor exposure and answer funder questions. If a Subpart F audit is required, the formal SEFA has specific content requirements. 2 CFR 200.510(b)

Reconciliation element	Practical control
Federal agency and program	Map each award to its Assistance Listing number or other required identifier.
Pass-through funding	Retain the pass-through entity name and assigned identifying number.
Federal expenditures	Reconcile program totals to the ledger and applicable expenditure rules.
Subrecipient payments	Identify amounts provided to subrecipients by federal program.
Schedule notes	Describe significant accounting policies and the de minimis election when applicable.
Special assistance types	Flag loan balances and other items needing separate review.

Do not make the reconciliation depend on a single employee’s memory. Retain the crosswalk from ledger codes to awards, explanations for excluded funding, and evidence supporting material corrections. Have program staff confirm whether all active agreements are on the register, while finance staff validate the financial population.

Plan the FAC deadline backward

The current submission rule requires the audit, data collection form, and reporting package within 30 calendar days after receipt of the auditor’s reports or nine months after the audit period ends, whichever is earlier. It provides for authorized extensions in specified circumstances and shifts a due date falling on a weekend or federal holiday to the next business day. Do not assume an extension exists without authorization. 2 CFR 200.512(a)

As a hypothetical planning example, a June 30 year-end suggests a nine-month reference date of March 31 of the following year. But receiving the auditor’s report on February 10 may trigger an earlier deadline under the 30-calendar-day rule. Calculate the actual date, including applicable calendar adjustments, and assign someone to record report receipt immediately.

The reporting package includes financial statements and the SEFA, the summary schedule of prior audit findings, auditor reports, and a corrective action plan. The auditee submits electronically to the FAC. Senior management and the auditor have separate certification responsibilities, and protected personally identifiable information must not be included. 2 CFR 200.512(b)–(d)

Set internal dates for drafting, management review, certification, and final submission. Save proof of completion rather than treating a prepared package or an unfinished upload as a submitted audit.

Below the threshold does not mean beyond oversight

A nonprofit below the applicable threshold is not exempt from its grant obligations. The revised rule preserves access to records for review or audit by appropriate federal officials, pass-through entities, and the Government Accountability Office, and references exceptions under 2 CFR 200.503. Separate state, contractual, or board requirements may also require financial examination; review them independently. 2 CFR 200.501(e)

Do not stop documenting allowable costs, reconciling restricted funding, or resolving monitoring questions because the federal expenditure total is $950,000. Audit applicability and sound grant management answer different questions.

For general preparation steps, use our nonprofit annual audit checklist. For maintaining distinct funding records throughout the year, read our fund accounting overview. Neither substitutes for the current federal threshold and award-specific requirements.

Educational disclaimer: This article is general educational information, not legal advice or an audit determination. Confirm expenditure calculations, applicable exceptions, state requirements, and submission deadlines with your qualified auditor and responsible federal oversight or cognizant agency.

Sources

All sources accessed October 26, 2026. The eCFR text cited is the October 1, 2024 revision, which the live Part 200 version history identified as the latest revision date when checked.

• Federal Audit Clearinghouse, Is my organization required to conduct a Single Audit?: fiscal-year transition and thresholds.
• eCFR, 2 CFR 200.501, official section text: audit requirements, exemptions, and recipient-versus-contractor treatment.
• eCFR, 2 CFR 200.510, official section text: financial statements and SEFA requirements.
• eCFR, 2 CFR 200.512, official section text: submission timing, reporting package, certifications, and protected information.
• OMB, Guidance for Federal Financial Assistance, April 22, 2024 final guidance: award-level implementation and effective date.
• eCFR, live Part 200 version history: revision-date verification.