The 2026 OMB Compliance Supplement delay is here: OMB has once again fallen behind schedule on the annual Compliance Supplement, and this year’s delay is shaping up to be even more uncertain than last year’s. This guidance, which typically becomes available in May, gives auditors the framework they need to conduct Single Audits for organizations that receive federal funding. As of early September 2026, OMB has not released a final or even a draft version of the 2026 Compliance Supplement, leaving auditors and their clients with less to plan against than they had at this point last year.
Impact on Your Organization
If your organization receives federal funding and has a June 30, 2026, fiscal year-end or later, this delay is likely to affect the timing of your audit deliverables:
- Your Single Audit cannot be finalized until OMB releases the official 2026 Compliance Supplement.
- This may affect your ability to submit required audit reports to federal agencies, pass-through entities, or other funders within standard timeframes. Under the Uniform Guidance, Single Audit requirements for nonprofits generally include submitting the reporting package within nine months of fiscal year-end.
- Your financial statement audit can proceed and be issued separately, on schedule.
What to Expect Once the Supplement Arrives
While the details won’t be final until OMB publishes the official guidance, early indications point to a lighter set of changes than in past years. Auditors and industry groups are watching for a shift in terminology from “matching” to “cost sharing” throughout the document, along with possible realignment of certain federal programs under new Assistance Listing Numbers.
Neither change is expected to represent new funding or new compliance burdens; they are more likely to affect how existing requirements are labeled and organized. Organizations should also continue to apply the $1 million Single Audit threshold and the 15% de minimis indirect cost rate that took effect for awards issued on or after October 1, 2024, as these remain in place regardless of when the new Supplement is released.
“We saw this same scenario play out last year, so our nonprofit audit teams already have a playbook for helping clients plan with confidence while we wait on OMB,” said Shannon Winter, Partner and Assurance Nonprofit Co-leader. “The delay is frustrating, but it doesn’t have to slow down the parts of your audit that are within your control.”
How We’re Helping Clients Prepare
Even without final guidance in hand, BPM’s Assurance colleagues are moving forward on your behalf. We’re using the most recent available information, along with prior-year guidance, to:
- Begin planning your Single Audit engagement.
- Identify likely compliance testing areas based on programs you’ve historically received.
- Prepare audit procedures in advance so we can move quickly once the final Supplement is released.
Let’s Talk Through What This Means for You
If you have funders or grantors who expect timely reporting, now is a good time to get ahead of the conversation. Let them know that this delay reflects an industry-wide, OMB-driven timing issue, not a gap in your organization’s compliance or your auditor’s readiness. BPM serves organizations across the Nonprofit industry and is closely monitoring the situation. We will notify you as soon as the final 2026 Compliance Supplement is released. If you have questions about how this delay affects your specific situation or need help communicating with your funders, please contact your BPM engagement team.
