2026 OMB Compliance Supplement Release Delay

Organizations that expend significant amounts of federal funding are closely monitoring the release of the 2026 Office of Management and Budget (OMB) Compliance Supplement. As of July 2026, the Supplement remains under review with no definitive release date, and professional organizations including the AICPA Governmental Audit Quality Center (GAQC) continue to advocate for prompt issuance or, at minimum, a draft version to help auditors and recipients of federal awards plan ahead.

For not-for-profit organizations requiring a Single Audit under Uniform Guidance, this delay carries real implications for audit timing, reporting deadlines, and communication with stakeholders. Not-for-profits should continue preparing audit documentation and SEFA support in the meantime, recognizing that issuance of the Single Audit reporting package itself may be delayed until the final Supplement is available. It's also a moment where experience matters. At Clark Schaefer Hackett, our Not-for-Profit Group has guided hundreds of NFP clients, from grassroots organizations to well-established institutions, through exactly this kind of regulatory uncertainty, and with the right advisor in your corner, this delay doesn't have to slow down your organization's progress.

The OMB Compliance Supplement serves as the primary source of audit guidance for Single Audits performed in accordance with the Uniform Guidance. It identifies program-specific compliance requirements, outlines auditor responsibilities, and provides testing guidance for federal programs.

Each year, auditors rely on the applicable Compliance Supplement to determine the compliance requirements that are subject to audit for major federal programs. Because federal programs, administrative requirements, and agency guidance can change from year to year, the applicable Compliance Supplement is a critical component of the audit process.

Current guidance indicates that auditors are expected to use the Compliance Supplement that is effective for the fiscal year under audit. As a result, Single Audit reports for fiscal years beginning after June 30, 2025, including many organizations with fiscal year ends of June 30, 2026 and later, should generally not be issued until the final 2026 Compliance Supplement is released.

While the Single Audit reporting package may need to be delayed, in many cases auditors may still be able to issue the financial statement audit separately if circumstances warrant. Organizations should consult with their auditors regarding any reporting requirements imposed by federal agencies, state agencies, lenders, bondholders, grantors, or other stakeholders.

The delayed release may affect a broad range of entities subject to Uniform Guidance requirements, including nonprofit organizations receiving federal grants, community action agencies, healthcare organizations receiving federal funding, educational institutions, local governments and special districts, housing authorities, social service organizations, and other entities expending federal awards above the Single Audit threshold.

Organizations with significant federal funding from agencies such as the U.S. Department of Health and Human Services (HHS), U.S. Department of Education, U.S. Department of Housing and Urban Development (HUD), U.S. Department of Agriculture (USDA), and other federal agencies may experience the greatest impact because auditors cannot finalize compliance procedures until the applicable guidance is available.

CSH performs an average of 240 Single Audit engagements each year, giving our team a broad, current view of how these delays play out across sectors and agencies, and how best to plan around them.

Board members and management teams should recognize that this situation is largely outside the control of both the organization and its auditors. The delay reflects the timing of federal guidance issuance rather than concerns about audit quality or compliance performance. While the issuance of Single Audit reports may wait on OMB, audit planning, documentation, and financial statement reporting can continue in the meantime.

Organizations that begin planning now, maintain complete grant documentation, and communicate proactively with stakeholders will be best positioned to complete their Single Audit efficiently once the 2026 Compliance Supplement is released. Clark Schaefer Hackett has guided more than 700 not-for-profit clients through moments like this, offering Single Audits, agreed-upon procedures, employee benefit plan audits, financial statement audits, grant compliance process design, and Form 990 support along the way.

Ready to talk through what this delay means for your organization? Connect with a CSH not-for-profit advisortoday to start the conversation and build a plan that keeps your audit, your reporting, and your stakeholders on track.

OMB Compliance Supplement information and resources: White House OMB Compliance Supplement page

AICPA & CIMA 2026 Compliance Supplement and Single Audit Update: AICPA & CIMA webcast information

Note: This article is intended for general informational purposes and should be evaluated in light of each organization's facts, grant agreements, applicable filing requirements, and auditor guidance.