Preparing for 2026 Single Audit Changes: Key Considerations for Organizations that are Subject to the Uniform Guidance

The single audit environment continues to shift for organizations that receive and administer federal funding and are subject to the Uniform Guidance. Several changes have recently been proposed, expected to be issued or issued that will be taken into effect over the next couple of years. Federal agencies are placing greater emphasis on transparency, accountability, and oversight. Proposed changes to the Uniform Guidance may create new expectations for grant management, documentation and compliance. Organizations should begin assessing how these developments will affect their programs, funding strategies and audit readiness.

As of late July 2026, the 2026 OMB Compliance Supplement had not yet been issued, but several expected updates provide insight into where grant recipients and auditors should focus. The Compliance Supplement remains a critical tool for identifying the compliance requirements subject to audit for major federal programs, including allowable costs, cash management, procurement, reporting, subrecipient monitoring and special tests. Understanding what has and how those changes affect internal controls, policies and day-to-day grant administration is only part of the equation.

What to Expect in the 2026 Compliance Supplement

Delays in the issuance of the compliance supplement by the OMB, continues to impact the timely performance of the single audit. The 2025 compliance supplement was not issued until late November 2025, and the 2026 compliance supplement is yet to be released.  Based on drafts shared by the OMB with the AICPA Government Audit Quality Center, the 2026 Compliance Supplement is expected to include limited changes. One notable terminology change is the expected shift from “matching” to “cost sharing” throughout the Compliance Supplement. While this may appear administrative, it is a reminder that organizations should periodically review grant policies, award documentation, budgets and internal communications to ensure terminology is consistent and aligned with federal expectations.

Organizations should also pay attention to realigned or decoupled programs. In some cases, federal agencies may create separate Assistance Listing Numbers for existing programs. These realignments are not expected to represent new programs because no new funding is involved; rather, they are intended to support agency reporting and align with current federal priorities. For audit purposes, realigned programs are expected to be treated as a cluster and may still count as audited in the prior two years for applicable look-back requirements.

Additional structural changes may affect how auditors and recipients navigate the Compliance Supplement. Part 2 is expected to identify realigned programs separately from new and deleted programs. Part 3 is expected to return to a single section, rather than being split into Parts 3.1 and 3.2. Part 6, historically focused on internal controls, is expected to be removed as part of OMB’s broader streamlining efforts. Even if the Supplement becomes more concise, organizations should not interpret this as a reduced need for strong internal controls over compliance.

Why Risk Designations and Resubmissions Matter

The 2026 update is also expected to address higher-risk program designations. Programs expected to be identified as higher risk include the Medicaid Cluster, the Child Care and Development Fund Cluster and Temporary Assistance for Needy Families program. The Abandoned Mine program is expected to no longer be designated higher risk. These designations can influence audit planning, major program determination and the level of scrutiny applied to certain awards by independent auditors and federal awarding agencies

The Federal Audit Clearinghouse is also developing a process for single audit resubmissions in coordination with agency partners and OMB. A full resubmission may generate a new acceptance date, which could affect low-risk auditee status. A partial resubmission is expected to retain the original acceptance date. Organizations should monitor forthcoming guidance and consider the potential audit and compliance implications before initiating a resubmission.

Proposed Uniform Guidance Revisions Could Reshape Grant Management

Beyond the changes in the 2026 Compliance Supplement, in May 2026, the OMB proposed a sweeping overhaul to 2 CFR Part 200 of the “Uniform Grant Guidance”. The proposed changes shift the framework from guidance to binding regulation and reclassifies it as the Uniform Grant Regulation.  The main structural and policy updates include

• Alignment with administration Priorities
• Expanded termination authority
• Applicant risk assessment
• New terms and conditions throughout the period of performance
• DEI restrictions
• Political and ideological prohibitions
• Changes to language access
• Hiring preferences
• Fixed amount awards
• Data privacy
• Multi year awards
• Additional mandatory and conflict of interest disclosures
• Administrative verification requirements

In summary, the operational implications could be significant. The proposals point to increased scrutiny around eligibility, alignment with federal priorities, award terms and program execution. Recipients and subrecipients may face expanded reporting requirements, including written justifications tied to project milestones or activities when requesting advances or reimbursements. These changes could require more robust documentation, stronger coordination between finance and program teams and earlier involvement from compliance personnel in grant planning.

Indirect cost rates are another area to watch. While the standard negotiation process would largely remain, agencies would be instructed to give preference to organizations with lower indirect cost rates on discretionary awards when other factors are equal. This may influence how organizations evaluate funding opportunities, budget for grant-funded programs and communicate the full cost of delivering services.

What Other Changes Should Organizations Prepare for

In addition to regulatory changes discussed above, the AICPA revised the AICPA audit guide for Government Auditing Standards and Single Audits.  The draft revisions were included in the 2025 version of the Audit Guide as Appendix B and are expected to be released in final form in the 2026 single audit guide.  While the changes do not impact organizations directly, they are expected to impact how auditors approach the single audit and feature enhanced risk assessments for identification and assessment of risk of material noncompliance, expanded IT evaluation by placing a greater emphasis on understanding and testing information technology related controls and applications, and stricter noncompliance evaluations when determining questioned costs and assessing how noncompliance impacts the overall auditors’ compliance opinion.

How Organizations Can Prepare

With multiple changes on the horizon, organizations subject to the Uniform Guidance should take a proactive approach to readiness. Finance, compliance and program leaders should assess whether current policies and procedures are designed to capture the documentation needed to support compliance with award terms. Organizations should also review internal controls over procurement, subrecipient monitoring, reimbursement requests, reporting and the Schedule of Expenditures of Federal Awards.

Organizations should also continue incorporating the 2024 Uniform Guidance revisions into their audit planning and grant administration processes. The single audit threshold was increased from $750,000 to $1 million in incurred federal expenditures for fiscal years beginning on or after Oct. 1, 2024, the de minimis indirect cost rate increased from 10% to 15%, and the thresholds for equipment and unused supplies increased from $5,000 to $10,000. These changes remain important for determining audit requirements, classifying costs and maintaining compliance.

The single audit process is most effective when organizations prepare before fieldwork begins. By reviewing grant agreements, strengthening documentation practices and aligning finance, compliance and program terms, organizations can better manage risk and respond to evolving federal requirements. As 2026 guidance becomes final, organizations should be ready to assess the impact quickly and adjust their processes accordingly.

Learn More

For more practical guidance on navigating the Uniform Guidance (Single Audit) process, register for CBIZ’s Preparing for a Successful Uniform Guidance (Single Audit) webinar on Aug. 12, 2026. The session will cover key compliance and internal control requirements, documentation best practices, common audit pitfalls and strategies for effective communication and planning.

How CBIZ Can Help

Connect with a CBIZ professional to assess the impact of changing federal grant requirements, strengthen internal controls and prepare for upcoming single audit considerations.