On September 29, 2026, the Office of Management and Budget (OMB) released a draft of the Compliance Supplement, similar to its approach for the 2025 Compliance Supplement. The draft may be used for planning purposes and to evaluate how the changes could affect audits for fiscal years ending after June 30, 2026 and beyond. In its press release, the AICPA noted that the draft “has not yet received final clearance from OMB leadership. OMB staff have also informed us that they do not expect any significant changes to result during the clearance process.” If this year’s process is similar to last year’s release, only minimal changes are expected. For additional context, final clearance last year was provided shortly before Thanksgiving for the 2025 Compliance Supplement.
Organizations that expended more than $1,000,000 in federal funding during the current fiscal year are encouraged to review the draft supplement and assess whether it includes significant changes affecting the programs in which they participate. As in prior years, Part 8, Section V, “List of Changes for the Compliance Supplement,” provides an outline of changes from the last compliance supplement.
Organizations are also encouraged to carefully evaluate programs designated as higher risk. This list changes each year based on input from awarding agencies and other federal priorities. The current-year list is available in Part 8, Section IV, “Higher Risk Designation.”
While we await the final compliance supplement, now is an ideal time to prepare and coordinate with your auditors so that your report can be issued promptly once the guidance is finalized. At this time, the federal government has not indicated that the deadline for submitting a final single audit to the Federal Audit Clearinghouse will change. These submissions are generally due within nine months after an organization’s fiscal year-end.
AICPA members can download the draft Compliance Supplement from the AICPA website.
