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Single Audit Requirements: The $1 Million Threshold, Major Programs and What Auditors Test
Last updated: October 10, 2026 · Independent guide · We do not sell rankings or coverage.
Single audit requirements apply to any US nonprofit, state or local government, school district, Indian tribe or college that spends $1,000,000 or more in federal awards in a fiscal year beginning on or after October 1, 2024. The audit, set out in Subpart F of the Uniform Guidance, combines a financial statement audit with compliance and internal control testing of your largest and riskiest federal programs. You prepare the schedule of expenditures of federal awards (SEFA) and the corrective action plan, and you file the package with the Federal Audit Clearinghouse (FAC) within nine months of year end. We checked the rules below in the eCFR on October 10, 2026, when it showed its text as up to date as of October 7, 2026.
The rule in brief
- Who: nonprofits, states, local governments, Indian tribes and colleges that spend federal awards as a recipient or subrecipient. For-profit organizations are outside Subpart F (2 CFR 200.501).
- Threshold: $1,000,000 for fiscal years beginning on or after October 1, 2024, and $750,000 for earlier years (FAC Help Center, November 7, 2024).
- Deadline: the earlier of 30 days after you receive the auditor’s report or nine months after year end (2 CFR 200.512).
- What is tested: the compliance requirements in the OMB Compliance Supplement for each major program.
- Official source: 2 CFR Part 200, Subpart F.
What a single audit requires
OMB’s 2024 revision of the Uniform Guidance raised the threshold from $750,000 to $1,000,000, effective October 1, 2024 (Federal Register, April 22, 2024). A June 30 school district first applies it to the year ending June 30, 2026.
The audit follows Government Auditing Standards and has three parts (2 CFR 200.514). The auditor gives an opinion on your financial statements and on whether the SEFA is fairly stated in relation to them, then tests internal control and compliance with the rules that could have a direct and material effect on each major program.
The results appear in the auditor’s reports, which may be combined or separate, and a schedule of findings and questioned costs whose summary lists the major programs and the Type A threshold used (2 CFR 200.515).
How auditors select major programs
Section 200.518 sets a four-step, risk-based process. Your auditor chooses, but your SEFA, audit history and filing record drive the outcome.
Step 1: Type A or Type B. Programs above the Type A threshold are Type A. All others are Type B.
| Total federal awards expended | Type A threshold |
|---|---|
| $1 million to $34 million | $1,000,000 |
| Over $34 million to $100 million | 3% of total expended |
| Over $100 million to $1 billion | $3,000,000 |
| Over $1 billion to $10 billion | 0.3% of total expended |
| Over $10 billion to $20 billion | $30,000,000 |
| Over $20 billion | 0.15% of total expended |
Step 2: Low-risk Type A programs. A Type A program is low risk if it was audited as major in at least one of the two most recent audits and, in the most recent one, had no material weakness, no modified opinion and no questioned costs above 5% of its expenditures.
Step 3: High-risk Type B programs. The auditor assesses only Type B programs above 25% of the Type A threshold, which is $250,000 for most auditees, and need not identify more than one-fourth as many high-risk Type B programs as there are low-risk Type A programs. Risk criteria in 200.519 include prior findings, weak subrecipient monitoring and new programs.
Step 4: Coverage. The auditor tests every Type A program that is not low risk, every high-risk Type B program, and enough others to cover 40% of total federal expenditures, or 20% for a low-risk auditee. To be a low-risk auditee under 200.520, you need, for each of the two preceding audits, on-time annual filing, unmodified opinions on the financial statements and SEFA, no material weaknesses, no going concern doubt and no serious findings on Type A programs.
Illustration. A county agency spends $4,200,000 in federal awards, so its Type A threshold is $1,000,000. Program A ($1,800,000) was major last year with no findings, so it is low risk. Program B ($1,200,000) was not major in the last two audits, so it is tested, and the auditor rates two smaller Type B programs as not high risk. Program B covers 28.6% of expenditures, enough for a low-risk auditee. If the agency filed late last year, the floor rises to 40% ($1,680,000) and another program must be added. These figures are illustrative.
What auditors test: the Compliance Supplement
The Compliance Supplement (Appendix XI to 2 CFR 200) sets out what auditors test for each program it covers. The current final edition is dated November 2025 (OMB, November 2025) and applies to fiscal years beginning after June 30, 2024 (Thompson Grants, November 26, 2025; Thompson sells grants compliance publications). OMB released a draft 2026 supplement on September 29, 2026 that had not received final clearance by October 5, 2026 (Schneider Downs, October 5, 2026; Schneider Downs is a CPA firm that sells audit services).
Part 2 of the supplement marks each requirement Y or N for each program. A Y requirement is tested only if it could have a direct and material effect on the major program (2025 Compliance Supplement, Part 2, no calendar date shown). Letters D and K are reserved. The right-hand column reflects common audit practice.
| Letter | Compliance requirement | Records auditors usually request |
|---|---|---|
| A, B | Activities allowed or unallowed; allowable costs | Invoices, journal entries and payroll records coded to the award |
| C | Cash management | Drawdowns compared with payment dates |
| E | Eligibility | Participant files |
| F | Equipment and real property | Asset register with funding source |
| G | Matching, level of effort, earmarking | Match detail by award |
| H | Period of performance | Transactions near award start and end dates |
| I | Procurement, suspension and debarment | Quotes, contracts, SAM.gov checks |
| J | Program income | Program revenue and its use |
| L | Reporting | Federal reports tied to the ledger |
| M | Subrecipient monitoring | Risk assessments, subawards, monitoring reviews |
| N | Special tests and provisions | Program-specific items listed in Part 4 |
Who is exempt
If you spend less than $1,000,000 in federal awards, you are exempt from Subpart F audits for that year, but your records must remain available to the federal agency, the pass-through entity and the GAO (2 CFR 200.501(e)). Contractor payments for goods or services do not count. If all your federal spending is under one program whose rules do not require a financial statement audit, you may elect a program-specific audit instead.
Deliverables and deadlines
Under 200.508, you arrange the audit, prepare the financial statements and SEFA, follow up on findings and give the auditor access to records. The package includes:
| Deliverable | Prepared by | Rule |
|---|---|---|
| Financial statements and SEFA with notes | You | 200.510 |
| Summary schedule of prior audit findings | You | 200.511(b) |
| Auditor’s reports and schedule of findings and questioned costs | Auditor | 200.515, 200.516 |
| Corrective action plan | You | 200.511(c) |
| Data Collection Form (SF-SAC) | You and the auditor, each certifying | 200.512(b) |
Major program selection starts from the SEFA. Our guide to the schedule of expenditures of federal awards explains how to build it, and our de minimis indirect cost rate guide covers the rate its notes must disclose.
Auditors must report significant deficiencies and material weaknesses over major programs, material noncompliance, known or likely questioned costs above $25,000 for a compliance requirement, and known or likely fraud (2 CFR 200.516). Your corrective action plan must be a separate document naming the contact person, the planned action and the completion date for each finding, or explaining in detail why you disagree (2 CFR 200.511).
The FAC takes the SF-SAC as eight Excel workbooks. Three are marked optional, and the other five cover federal awards, notes to the SEFA, findings, findings text and the corrective action plan (FAC, no date shown).
For a June 30, 2026 year end, the latest due date is March 31, 2027. Section 200.512 allows extensions for undue burden, but the FAC Help Center says federal agencies no longer grant extensions for single audit submissions (FAC Help Center, no date shown). Blanket extensions have followed declared disasters (COFFA memorandum, March 11, 2025).
Penalties for late or missing audits
If you remain unable or unwilling to have a required audit, agencies and pass-through entities must act under 200.505. The remedies in 200.339 include withholding payments, disallowing costs, suspending or terminating awards, suspension or debarment proceedings and withholding future awards. A late filing also removes low-risk auditee status for two years, doubling minimum coverage to 40%.
Records you must keep
Keep the reporting package and Data Collection Form for three years from FAC submission (2 CFR 200.512). Award records must be kept for three years from submission of the final financial report, and longer if an audit, claim or litigation starts first; equipment records run three years past disposal (2 CFR 200.334).
What to set up in your systems
Section 200.302(b) requires your system to identify each award by Assistance Listing number, award number, year and federal agency or pass-through entity. Create one grant value per award with those attributes, code every transaction to it at entry, and give your auditor read-only access.
Sage Intacct tracks grants with the project dimension or the Projects application, which flags billable expenses for reimbursement requests. A GL report filtered by grant and period gives backup detail, though Sage says the dimension-only method keeps a less detailed history (Sage Intacct Help, last modified October 8, 2026). Sage documents a read-only user setup for external auditors and an audit trail showing who changed a record and when (Sage Intacct Help, last modified October 8, 2026). We found no standard SEFA report in Sage’s documentation.
Blackbaud Financial Edge NXT keeps grant and project records with history, budgets across grant periods, allocations and reimbursement calculations, with drill-down from a grant to transaction detail (Blackbaud, last modified May 14, 2026). The page does not mention the Uniform Guidance or Assistance Listing fields, so ask how you would store them.
MIP Fund Accounting (formerly Abila MIP, now part of Momentive Software) (Momentive Software, last modified July 28, 2026) uses a multidimensional chart of accounts and grant records holding grantor, grant period, reporting periods and indirect cost rate (MIP, last modified February 12, 2024). MIP partner REDW sells SEFA Pro, an add-on that produces SEFA reports and grant reconciliations from MIP data (REDW, last modified July 16, 2026).
None of these vendors publishes pricing. For wider comparisons, see our grant management software guide and nonprofit accounting software guide.
How we researched this
We read the eCFR text of 2 CFR 200.302, 200.334, 200.339 and 200.501 to 200.520 on October 10, 2026, the 2024 Federal Register notice, FAC guidance and the 2025 Compliance Supplement. We also read the top-ranking pages for this topic and vendor documentation for each product named. No vendor paid for or reviewed this article.
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Frequently asked questions
What is the single audit threshold for 2026?
It is $1,000,000 in federal expenditures for fiscal years beginning on or after October 1, 2024. Fiscal years that began earlier used $750,000. The test is money spent, not awarded.
When is the single audit due?
It is due to the FAC 30 days after you receive the auditor’s report or nine months after year end, whichever comes first. Plan on that date, because the FAC says federal agencies no longer grant extensions.
Which Compliance Supplement applies to a fiscal 2026 audit?
The 2025 supplement was the final edition in early October 2026. A draft 2026 supplement was released on September 29, 2026 for planning, so ask your auditor which edition applies.
Do we need a corrective action plan if we disagree with a finding?
Yes. The plan must address every current-year finding, and where you disagree it must explain why in detail.
Sources
- eCFR, 2 CFR Part 200, Subpart F, sections 200.501, 200.505, 200.508, 200.510, 200.511, 200.512, 200.514, 200.515, 200.516, 200.518, 200.519 and 200.520, up to date as of October 7, 2026. ecfr.gov
- eCFR, 2 CFR 200.302, 200.334 and 200.339, up to date as of October 7, 2026. ecfr.gov
- OMB, Guidance for Federal Financial Assistance, 89 FR 30046, April 22, 2024. federalregister.gov
- OMB, Compliance Supplement page, November 2025. whitehouse.gov
- OMB, 2025 Compliance Supplement Part 2 matrix, no calendar date shown. whitehouse.gov
- Thompson Grants, OMB Releases Final 2025 Compliance Supplement, November 26, 2025. thompsongrants.com
- Schneider Downs, 2026 Compliance Supplement Update, October 5, 2026. schneiderdowns.com
- FAC Help Center, Is my organization required to conduct a Single Audit?, November 7, 2024. support.fac.gov
- FAC Help Center, How do I request an extension on the due date?, no date shown. support.fac.gov
- FAC, SF-SAC workbooks and Audit Submission Guide, no date shown. fac.gov
- Council on Federal Financial Assistance, single audit extension memorandum, March 11, 2025. fac.gov
- Sage Intacct Help, Grant tracking and billing; Set up an auditor as a user, last modified October 8, 2026. intacct.com
- Blackbaud, Financial Edge NXT grant and program accounting, last modified May 14, 2026. blackbaud.com
- MIP Fund Accounting, product page covering Grant Administration and Chart of Accounts, last modified February 12, 2024. mip.com
- Momentive Software, Abila has moved, last modified July 28, 2026. momentivesoftware.com
- REDW, SEFA Pro, last modified July 16, 2026 (REDW sells the add-on). redw.com
Sherman Hsieh
Independent analysis of enterprise software — ERP, CRM and more
