What Do 2026 Compliance Supplement Delays Mean for Your Nonprofit’s Single Audit?

Understanding the potential impact on Single Audit timing and the steps your organization can take while awaiting the final Supplement

What is the Compliance Supplement?

The Compliance Supplement is a document that identifies compliance requirements that the federal government expects to be considered when testing major programs in a Single Audit. Single audits reports are the opinion on compliance in accordance with Uniform Guidance and must be performed when a not-for-profit organization expends more than $1,000,000 of federal funds for fiscal years beginning on or after October 1, 2024. The supplement has historically been published annually in May or early June in advance of the mid-year fiscal audits.

In 2025, there were unprecedented delays in the publication of the Compliance Supplement. A draft was published in August of 2025 and the final supplement did not follow until November 2025. On September 29, 2026, the draft of the 2026 Compliance Supplement was released but the final supplement publication date is still unknown.

This supplement will apply to audits of fiscal years beginning after June 30, 2025, meaning not-for-profit organizations with June 30, 2026, year ends or later fall within this cycle.

What does the delay mean for your nonprofit organization?

Although the Compliance Supplement is primarily an auditor’s tool, the delay can have a direct effect on your reporting timeline. According to the AICPA Governmental Audit Quality Center (“GAQC”), auditors cannot issue a single audit report until the Office of Management and Budget (“OMB”) releases the supplement for the applicable period.

This matters because the filing clock does not stop. Not-for-profit organizations must submit single audit reports to the Federal Audit Clearinghouse (“FAC”), the earlier of 30 days after receiving the auditor’s report or 9 months after the end of the audit period. As of late September 2026, no broad extensions to those deadlines have been announced. The window between the supplements release and your filing deadline may be very short.

Keiter Insight: Your organization’s financial statement audit is not held up by this. Work can proceed on both the financial statement audit and single audit.

What do we know about the 2026 Compliance Supplement right now?

Two separate federal developments are important and worth keeping them distinct.

First, the supplement itself. OMB has not issued the 2026 version of the Compliance Supplement. Since the supplement is updated annually and the final report supersedes prior Supplements, auditors will have to wait until the final report is published to finalize single audit reports.

Second, the OMB originally had a targeted release date of October 1, 2026. When the Section 157 of the Continuing Appropriations Act, 2027 was signed on September 2, 2026, it temporarily barred the OMB from finalizing and issuing its proposed changes to the Uniform Guidance rule, or a “substantially similar rule”, through December 11, 2026. If any part of the rule is enacted before this date, the rule will have no force or legal effect through December 11, 2026. This essentially blocked the OMB’s planned October 2026 implementation date. While Section 157 does not govern the Compliance Supplement directly, it is reasonable to expect that a final 2026 compliance supplement will not be released until the ban lifts on December 11, 2026, or even after.

Based on drafts, OMB has shared with the GAQC the 2026 Supplement is expected to include limited changes. The most visible are:

• The terminology shift from “matching” to “cost sharing” throughout the document
• Certain programs may also be realigned under new assistance listing numbers or clusters
• Some high-risk programs were removed and TANF and CCDF programs will be considered high risk programs
• Federal Funding Accountability and Transparency Act (FFATA) reporting will be required for all major programs where the requirement is applicable.

What can nonprofits do right now?

The proposed Uniform Guidance rewrite is not the current standard. DO NOT revise policies or procedures based on a proposed rule.

Organizations can stay active to remove obstacles that could impact their ability to have their single audit report filed timely. You can work closely with your audit team to plan and prepare for a quick turnaround on the single audit report.

Auditors can begin planning for single audits and perform testing around the major program(s) under audit drawing on the draft 2026 Compliance Supplement, current grant agreements, federal program sources, and other available information. Once the final supplement is published, auditors will compare compliance requirements for each tested major program against the work already performed. Any gaps identified may require auditors to update testing, request additional documentation, or other support from your organization. While this approach may seem cumbersome initially, completing this work upfront can help streamline the single audit process and facilitate timely issuance and filing of the report.

If your board, lender, or funders require issued financial statements on a set timetable, consider decoupling the deliverables: issue the financial statements on schedule and finalize the Single Audit reporting package separately once the supplement is released. It is less streamlined than a combined issuance, but it protects the commitments you have already made.

Lastly, it is important to note that the release date of the 2026 Compliance Supplement is outside of anyone’s control, but the readiness of your organization is not. Keiter’s not-for-profit and Single Audit professionals are actively working with clients on exactly this planning, and we are monitoring OMB and GAQC developments closely, so you don’t have to.

If you have questions about how the delay affects your nonprofit’s fiscal year, or you would like help building a readiness plan, please reach out to your Keiter Not-for-Profit Opportunity Advisor. Email