Single audit threshold: does your nonprofit need one this year?
Under the Uniform Guidance, a nonprofit that expends $1,000,000 or more in federal awards in its fiscal year needs a single audit (or, in narrow cases, a program-specific audit). The test is money expended in the year, not money awarded. Here is how to run it on your own numbers.
The method
- Pick the fiscal year you are testing. The test is run per fiscal year of the organization, not per grant and not per award period.
- List every federal award you spent from in that year. Include federal money that reached you through a state, county or other pass-through entity. As read on 2026-11-02, 2 CFR 200.501(g) says awards expended as a recipient or as a subrecipient are both subject to audit. Ask each pass-through entity whether its money is federal and what its assistance listing number is. Foundation grants and ordinary contracts you win on price are not federal awards.
- Count when the activity happened, not when cash moved. Under 200.502(a), as read, expended is based on when the activity related to the award occurs: expenditures, disbursements to subrecipients, receipt or use of program income and similar events. A grant you were awarded but did not touch this year adds nothing; spending against last year's cash does.
- Take out contractor payments. 200.501(g), as read, says payments you receive for goods or services you provide as a contractor under a federal award are not subject to audit under this part. Be careful with the label: whether you are a subrecipient or a contractor is decided by the substance of the arrangement, so ask the pass-through entity if it is unclear.
- Add it up and compare it to $1,000,000. At $1,000,000 or more, 200.501(a) and (b) require a single audit, except where you elect a program-specific audit under (c) or (d): that is only open if you expend federal awards under a single federal program and the program does not require a financial statement audit. Below $1,000,000, 200.501(e) exempts you from the federal audit requirement for that year.
- If you are under, keep the records available anyway. Even in an exempt year, 200.501(e) as read says your records must be available for review or audit by the federal agency, the pass-through entity and the Government Accountability Office.
- If you are over, work out the due date now. Under 200.512(a)(1), as read, the audit, the data collection form and the reporting package are due within 30 calendar days after you receive the auditor's report or nine months after the end of the audit period, whichever is earlier, and go to the Federal Audit Clearinghouse. Engage an auditor early; this is not a deadline to meet by starting in month eight.
- Check the other triggers. A state, a lender, a foundation or your own bylaws can require an audit below the federal threshold. This page cannot tell you which apply to you. Ask your auditor or counsel.
Your award agreement and your funder's instructions are the authority on every date and requirement. This page is a working method, not legal, audit or compliance advice.
A worked example (made-up organization)
A nonprofit with a December year end spends $610,000 from a direct federal grant and $430,000 from a federal program passed through the state, $1,040,000 in federal awards expended in 2027. It also spends $200,000 from a private foundation, which is not federal and does not count. The total is over $1,000,000, so a single audit is required for 2027. Its auditor delivers the report on 15 August 2028. Thirty days after that is 14 September 2028; nine months after the year end is 30 September 2028. The earlier date, 14 September, is the due date.
Had the same organization spent $940,000 in federal awards, it would be exempt from the federal audit requirement for that year, would still keep its records available for review, and would still have to follow any audit term in its agreements.
Where it goes wrong
- Using awards instead of expenditures. A $2 million award spent at $300,000 a year does not trigger an audit in year one.
- Missing pass-through money. State and county subawards of federal funds are federal awards expended for this test.
- Quoting an old threshold. Articles written before the 2024 revisions may show a different figure. Check the date on anything you read against the current text.
- Starting late. The nine-month clock runs from the end of your fiscal year whether or not an auditor is engaged.
The faster path, and what it does not do
GrantClose does not calculate what you expended, decide whether you need an audit or prepare one. It helps with the part auditors and funders ask for afterwards: each award's letter, its deliverables with owners and due dates, and the evidence for each, in one place per award, exportable as a ZIP with an index and a SHA-256 checksum per file. A closed award stays readable and exportable on every plan, Free included.
- It holds only what you upload, up to 15 MB per file. It is not your general ledger or your audit workpapers.
- Do not upload health records, Social Security numbers, payment card data or client case files. The terms prohibit them.
GrantClose keeps each award's documents and deliverable evidence in one place and exports a ZIP when the award ends. GrantClose never submits anything to a funder, writes your reports or gives legal, audit or compliance advice. Extracted dates are suggestions you confirm. Free for 1 active award. Create a free account
Questions
What is the single audit threshold?
As read on 2026-11-02, 2 CFR 200.501 requires a single audit or program-specific audit for a non-federal entity that expends $1,000,000 or more in federal awards during its fiscal year.
Is the threshold based on money awarded or money spent?
Money expended. Under 200.502(a) it is based on when the activity related to the award occurs, such as expenditures and disbursements to subrecipients.
Does money passed through a state or county count?
Yes if it is federal money. 2 CFR 200.501(g) as read says awards expended as a recipient or as a subrecipient are subject to audit. Ask the pass-through entity to confirm the source.
What if we spent less than $1,000,000 in federal awards?
You are exempt from the federal audit requirement for that year, but 200.501(e) says your records must still be available for review by the federal agency, the pass-through entity and GAO. Other audit rules may still apply.
When is the single audit due?
Under 200.512(a)(1) as read: within 30 calendar days after you receive the auditor's report or nine months after the end of the audit period, whichever is earlier.
Sources read
- 2 CFR 200.501, audit requirements, read on 2026-11-02.
- 2 CFR 200.502, basis for determining federal awards expended, read on 2026-11-02.
- 2 CFR 200.512, report submission, read on 2026-11-02.