The Single Audit threshold is $1,000,000 in federal awards expended during your fiscal year. That is the whole rule, and it is the easy part. The hard part is knowing whether you are over it, and the organizations that get caught out are usually not careless. They are counting the wrong thing.

The number, and the date that decides which number applies to you

For 27 years the threshold was $750,000. OMB's 2024 revisions to the Uniform Guidance raised it to $1,000,000, codified at 2 CFR 200.501. It was the first change since 1997, which tells you roughly how often this gets revisited.

The effective date is where people trip. The $1 million threshold applies to fiscal years beginning on or after October 1, 2024. Not fiscal years ending after that date. Beginning.

So:

  • Calendar-year organization: your year that started January 1, 2025 was your first $1 million year.

  • July through June: your year that started July 1, 2025 was your first.

  • Year ended June 30, 2025: that year began July 1, 2024, which is before the cutoff. Your threshold for that year was still $750,000.

If you have a prior year still open, or an auditor asking questions about one, confirm which threshold governed it before you assume you were under.

"Expended" is the word doing the work

The regulation says Expended. It does not say awarded. It does not say received.

This matters more than almost anything else in the rule. A three-year, $3 million federal award does not put you in Single Audit territory the day it is signed. A single year in which you draw down and spend $1.1 million of it does.

The reverse happens too, and that is the version that bites. An organization can hold several million dollars in active awards, feel every bit like a major federal grantee, and stay under the threshold for years because the spending is spread thin. Then one year a construction draw lands, or a program ramps up, or two grants overlap, and the total clears $1 million without anyone making a decision to get bigger.

Your bank balance is not the measure either. Restricted cash sitting in the account is a liability on your books, not an expenditure.

A few categories do not follow the plain-English version of "expended." 2 CFR 200.502 sets out special rules for federal loan and loan guarantee programs, non-cash assistance such as donated food or equipment, endowment funds, and Medicare and Medicaid payments. If any of those are in your mix, get the calculation confirmed rather than assumed. The loan rules in particular can put a startlingly large number on your schedule.

Pass-through money is still federal money

This is the single most common reason an organization is surprised.

Federal money does not have to arrive from a federal agency to count. If it reaches you through a state agency, a county, a city, a university, or another nonprofit, you are a subrecipient, and those expenditures go on your schedule exactly like a direct award. Whose logo is on the agreement changes nothing.

How to tell:

  • Look for an Assistance Listing Number on the award document, a number like 93.600 or 97.036. Older paperwork may still call it a CFDA number.

  • Check whether the agreement names a federal awarding agency or cites 2 CFR 200. Both are strong signals.

  • If the terms flow down federal requirements (procurement standards, time and effort documentation, audit language), that money came from somewhere federal.

If your award letters are vague, ask the pass-through entity directly. They are required to identify the federal award to you. A one-sentence email now is considerably cheaper than finding out during fieldwork.

If you are in Western North Carolina, read that twice

Helene recovery money is federal money, and a great deal of it is arriving as subawards.

NC Emergency Management says this plainly in its own grants compliance FAQ: 2 CFR Part 200 applies to its major grant programs, the audit requirements apply to all recipients and subrecipients of federal funds, and the $1,000,000 threshold specifically includes federal funding passed through state agencies. The state is the recipient of FEMA money. Your organization, if it took a subaward, is the subrecipient.

Here is the scenario worth worrying about. An Asheville-area nonprofit ran a $400,000 budget before the storm. Since then it has picked up recovery work: housing assistance, debris and rebuilding support, case management, maybe a facility repair. None of it came from a federal application it filed. All of it came through the state or a county or a larger nonprofit. That organization can clear $1 million in federal expenditures in a single fiscal year and have no idea it happened.

It has almost certainly never had a Single Audit. It may never have had an audit at all.

If that could be you, the move is not complicated. Pull every recovery-related agreement you have signed since the storm, identify the federal program behind each one, and total what you have actually spent this fiscal year. Do it now, while you can still plan around the answer.

What actually changes when you cross

A Single Audit is not your financial statement audit with a few extra pages. It is a separate compliance audit performed alongside it, under Subpart F of 2 CFR Part 200, government auditing standards, and that year's OMB Compliance Supplement.

What you take on:

  • A Schedule of Expenditures of Federal Awards. The SEFA lists every federal award by program and Assistance Listing Number, direct and pass-through, with totals. It is the document the whole audit is built on.

  • Major program determination. Your auditor sorts programs into Type A and Type B by size, then risk-assesses them. The Type A threshold also rose to $1 million for organizations expending $34 million or less in total federal awards, up from $25 million.

  • Compliance testing on the major programs against the specific requirements in the Compliance Supplement: allowable costs, eligibility, reporting, subrecipient monitoring, and the rest.

  • A reporting package submitted to the Federal Audit Clearinghouse, due the earlier of 30 days after you receive the auditor's report or nine months after your fiscal year end.

  • A corrective action plan if there are findings, plus a summary schedule of prior findings in subsequent years.

One narrower option exists. Under 2 CFR 200.501, an organization that expends federal awards under only one federal program, where that program does not itself require a financial statement audit, may elect a program-specific audit instead. It is a real cost saving when you qualify. Most organizations do not.

Budget and calendar both deserve attention here. Auditors who do Single Audit work are a smaller group than general nonprofit auditors, and their spring calendars fill early. Discovering in March that you crossed the line last June is an expensive conversation to have.

Under the threshold is not off the hook

Your award terms may also require an audit on their own, independent of the threshold entirely.

North Carolina adds a second test. Under G.S. 143C-6-23 and 09 NCAC 03M, a non-State entity that receives, holds, uses, or expends State grant funds has its own reporting level, and at Level II it owes a single or program-specific audit under State law. Since July 1, 2024 that line points at the same figure as 2 CFR 200.501(a), so today it is also $1,000,000. For fiscal years ending July through September 2024 it was $750,000, and on or before June 30, 2024 it was $500,000.

The two tests are not alternatives. 09 NCAC 03M reaches State funds and federal funds passed through a State agency, which means a Helene subaward routed through a North Carolina agency is counted once under the federal rule and again under the State rule, on two separate determinations with two separate filings.

One related change worth knowing while you are in here. The de minimis indirect cost rate rose from 10% to 15% of modified total direct costs under 2 CFR 200.414(f), in the same 2024 revision that moved the audit threshold. If you do not have a negotiated indirect cost rate and you are still budgeting 10% on proposals, you are leaving money on the table every time.

The rule rewrite, and why it has not changed anything yet

You may have heard the Uniform Guidance is being rewritten. It is. It is also currently stuck, and the distinction matters for what you do this year.

On May 29, 2026, OMB published a proposed rule that would comprehensively revise 2 CFR Part 200 and rename it the Uniform Grants Regulation, elevating it from guidance to regulation in its own right. The comment period closed July 13, 2026, drawing close to half a million comments. OMB targeted an effective date of October 1, 2026.

That date came and went. Section 157 of the Continuing Appropriations Act, 2027, signed September 2, 2026, bars OMB from issuing or finalizing that rule, or a substantially similar one, through December 11, 2026 (CRS overview).

Two things to hold onto:

  • The proposal does not move the $1 million threshold or the 15% de minimis rate. Both were set in the 2024 revision, and the 2026 proposal leaves them where they are. Whatever happens in December, the number in this post is the number.

  • The current Uniform Guidance is your compliance baseline until a final rule is issued with its own effective date. Keep following it, your award terms, and the applicable Compliance Supplement.

One practical side effect: the 2026 Compliance Supplement is widely expected to run late, because it is entangled with the same rulemaking. If your auditor has not raised that with you yet, they will.

This section is accurate as of October 27, 2026. December 11 is close enough that it is worth a fresh check before relying on it.

What to do before your fiscal year closes

Four things, roughly in order of how much trouble each one saves.

  1. Total your federal expenditures year to date, this week. Direct and pass-through together, on the same basis your books use. If the number is anywhere north of $800,000, plan as though you will cross.

  2. Build the SEFA as you go, not in August. Every federal award should be identifiable in your accounting system by program, with its Assistance Listing Number and its pass-through entity recorded. In QuickBooks Online that usually means tracking each award as its own Project, so expenditures by award come straight out of the system instead of out of a spreadsheet somebody reconstructs every spring.

  3. Confirm the federal source behind every pass-through agreement. If you cannot name the federal program behind a state or county subaward, you cannot put it on a schedule, and you do not actually know whether you are over.

  4. Talk to your auditor early if you expect to cross. Scheduling, fee, and readiness all improve with lead time, and none of them improve without it.

The threshold is one number, and it has not moved since 2024. Whether you are over it is a bookkeeping question, answered monthly, long before it ever becomes an audit question.

If you are not certain where your organization stands, that is a reasonable place to be, and it is a question we work through with nonprofits fairly often.

Sources

The May 29, 2026 proposed rule is "Regulation for Federal Financial Assistance," Federal Register document 2026-10817, docket OMB-2026-0034.