2 CFR 200 Uniform Guidance: The 2024 Numbers in One Table

Full answer: 2 CFR 200, the Uniform Guidance, is the federal rule set for grant management, costs, and audits; its 2024 revision set a 15% de minimis rate and a $1,000,000 audit threshold. Under 2 CFR 200.414, a recipient without a negotiated indirect cost rate may elect up to 15% of Modified Total Direct Costs (MTDC), and MTDC counts only the first $50,000 of each subaward. Equipment starts at the lesser of your capitalization level or $10,000. A non-federal entity that spends $1,000,000 or more in federal awards in its fiscal year needs a Single Audit or permitted program-specific audit.

This guide is for grants managers, compliance officers, CFOs, sponsored-research administrators, nonprofit finance leads, and pass-through entities updating policies for the 2024 Uniform Guidance revisions.

2 CFR 200 Uniform Guidance: 2026 Rules and Checklist

Data note: Regulatory thresholds and requirements reflect the 2024 Uniform Guidance revision (effective October 1, 2024) per 2 CFR Part 200. Verify current requirements at ecfr.gov.

Source review by Grantsights, July 27, 2026: We checked the current eCFR text and OMB's 2024 final rule. According to OMB's final rule, section 200.414 allows recipients and subrecipients without a current federal negotiated indirect cost rate to elect up to 15% of MTDC. Section 200.1 includes only the first $50,000 of each subaward in MTDC, regardless of its period of performance. It defines equipment using the lesser of the organization's financial-statement capitalization level or $10,000. According to 2 CFR 200.501, the audit threshold is $1 million in federal expenditures during the fiscal year.

If you work in grants management, the 2 CFR 200 Uniform Guidance is the regulatory foundation for everything you do. It's the single document that tells you how to manage federal money, what you can spend it on, and how you'll be audited. Whether you're a grants manager at a small nonprofit or a compliance director at a research university, this regulation applies to you.

Who this is for: grants managers, compliance officers, financial administrators, and organizational leaders at nonprofits, universities, state agencies, local governments, and tribal governments that receive federal funding. If federal dollars flow through your organization, you need to understand the 2 CFR 200 Uniform Guidance and what it requires.

This guide separates the current rule text from practical implementation steps. Use it to identify the controlling section, update internal procedures, and find the award-specific condition that can change the answer.

Last updated: July 27, 2026

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The History: How 8 Circulars Became 1 Regulation

Before 2014, federal grants management was governed by a confusing patchwork of Office of Management and Budget (OMB) circulars. Different entity types followed different rules:

This created real problems. A university subawarding to a nonprofit had to understand both A-21 and A-122 cost principles. A state agency passing funds to a local government and a nonprofit needed to apply different administrative rules to each subaward. The system was fragmented, and it produced inconsistent treatment across entity types.

In 2013, OMB published the final Uniform Guidance under 2 CFR Part 200, consolidating all eight circulars into one regulation. It took effect on December 26, 2014. The consolidation wasn't just cosmetic. It harmonized cost principles so that the same rules apply whether you're a university, nonprofit, or government entity. It simplified procurement thresholds. And it created a single framework for everyone.

The First Policy Check

Search your current policies, templates, and training materials for the old circular numbers and superseded thresholds. A policy that still cites A-21, A-87, A-110, A-122, or the former $750,000 Single Audit threshold instead of the current $1,000,000 threshold can send staff to an obsolete rule. Map each operational policy to the current section of 2 CFR 200 and to any award-specific condition that changes it.

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The 6 Subparts of 2 CFR 200: What Each One Covers

The Uniform Guidance is organized into subparts, each addressing a different aspect of federal grants management. Here's what's actually in each one and what matters most for day-to-day compliance.

Subpart A: Acronyms and Definitions (200.0 through 200.1)

Don't skip this section. The definitions in Subpart A are legally binding, and many compliance disputes come down to how a term is defined. Key definitions that matter in practice:

• Federal award (200.1): Includes grants, cooperative agreements, and cost-reimbursement contracts. Doesn't include procurement contracts or fixed-price contracts.
• Non-federal entity: States, local governments, Indian tribes, institutions of higher education, and nonprofit organizations. This defines who the UG applies to.
• Modified Total Direct Costs (MTDC): The base for calculating the de minimis indirect cost rate. Excludes equipment, capital expenditures, participant support costs, and the portion of subawards exceeding $50,000.
• Period of performance: The time during which the non-federal entity may incur new obligations to carry out the work authorized under the award.
• Subaward vs. contract: This distinction determines whether you're a pass-through entity with monitoring obligations or simply a buyer of goods/services. Getting this wrong has cascading compliance implications. See our subrecipient monitoring guide for details.

Subpart B: General Provisions (200.100 through 200.113)

Subpart B establishes the purpose, applicability, and authorities behind the regulation. It confirms that the UG applies to all federal agencies making awards to non-federal entities. It also addresses:

• The relationship between the UG and agency-specific regulations
• Effective dates for amendments
• Conflict of interest requirements (expanded in 2024)
• Mandatory disclosures of violations

For most practitioners, Subpart B is background context rather than daily operational guidance. But section 200.112 on conflict of interest is worth reading carefully.

Subpart C: Pre-Federal Award Requirements (200.200 through 200.216)

This subpart governs the federal side of the process: how agencies announce funding opportunities, evaluate applications, and make awards. It covers:

• Merit review processes
• Funding opportunity announcements
• Standard application requirements
• Risk assessment of applicants
• Federal awarding agency review of award terms

Subpart C matters less for post-award compliance but is critical for understanding what federal agencies are supposed to do before making an award. When you see inconsistencies in your Notice of Award, Subpart C is the section to reference.

Subpart D: Post-Federal Award Requirements (200.300 through 200.346)

This is where the operational rules live. Subpart D is the section grants managers use most frequently. It covers:

Financial management (200.302): Your accounting system must identify the source and application of federal funds, separate federal funds from non-federal funds, and maintain adequate internal controls. This is the foundation for everything else.

Internal controls (200.303): You must establish and maintain effective internal control over federal awards that provides reasonable assurance that you're managing awards in compliance with applicable requirements. The 2024 revision specifically references established frameworks like COSO.

Payment (200.305): Rules for federal payment methods, including the advance payment and reimbursement models, and requirements for minimizing the time between drawdown and expenditure. See our federal grant drawdown guide for details.

Cost sharing and matching (200.306): When matching is required, this section defines what counts as match, documentation requirements, and valuation methods. In-kind contributions must be documented and valued according to specific standards.

Program income (200.307): Income earned from grant-supported activities during the period of performance. The default treatment is additive (income adds to the project budget), but agencies can specify deductive or cost-sharing treatment.

Property standards (200.310 through 200.316): Rules for equipment, supplies, intangible property, and real property purchased with federal funds. Under the definition in 2 CFR 200.1, equipment has a useful life of more than one year and a per-unit acquisition cost that meets or exceeds the lesser of the organization's financial-statement capitalization level or $10,000. Common mistake: treating $10,000 as a universal floor when the organization's capitalization level is lower.

Procurement standards (200.317 through 200.327): These sections establish how you must purchase goods and services with federal funds. Competition requirements, conflict of interest in procurement, and documentation standards are all covered. Our procurement standards guide covers these in detail.

Subrecipient monitoring (200.332): Requirements for pass-through entities to monitor their subrecipients. This includes risk assessments, monitoring plans, and corrective action procedures.

Record retention (200.334): Generally 3 years from submission of the final financial report, with exceptions for property records, litigation holds, and unresolved audit findings.

Closeout (200.344): Requirements for closing out awards, including the 120-day timeline for submitting final reports, equipment disposition, and return of unexpended funds.

Subpart E: Cost Principles (200.400 through 200.476)

Subpart E answers the question every grants manager gets asked: "Can we charge this to the grant?" The answer depends on four tests that every cost must pass:

1. Allowable: The cost isn't on the list of specifically unallowable costs (200.421 through 200.476), and the award terms don't prohibit it.
2. Allocable: The cost benefits the federal award and can be assigned to it in proportion to the benefit received.
3. Reasonable: A prudent person would have incurred the cost, and the amount is consistent with what the market would bear.
4. Consistent: The cost is treated consistently across federal and non-federal activities. You can't charge something to a federal grant that you wouldn't charge to your own unrestricted funds in similar circumstances.

The cost principles section includes a detailed list of specific cost items with guidance on each. Some of the most commonly referenced include:

For a complete breakdown of cost allowability, see our allowable costs guide.

Subpart F: Audit Requirements (200.500 through 200.521)

Subpart F establishes the Single Audit framework. The key threshold: organizations expending $1,000,000 or more in federal awards during a fiscal year must undergo a Single Audit. For a deep dive, see our Single Audit guide.

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The 2024 Revision: What Changed and What It Means

The 2024 revision to 2 CFR 200, effective October 1, 2024, was the most significant update since the regulation's initial publication. Here are the changes that matter most:

Threshold Changes

De Minimis Rate Increase

The increase from 10% to as much as 15% of MTDC matters most for organizations without a current federal negotiated indirect cost rate. At $500,000 in MTDC, the five-percentage-point difference can materially change the budget, subject to the award terms and available funds.

The current eligibility test is whether the recipient or subrecipient lacks a current federal negotiated indirect cost rate, including a provisional rate. The rule no longer limits the election to organizations that have never received a negotiated rate. Once elected, the organization uses the de minimis rate for all federal awards until it chooses to receive a negotiated rate.

Conflict of Interest Requirements

Section 200.112 requires federal agencies to establish conflict-of-interest policies for federal awards. A recipient or subrecipient must disclose in writing any potential conflict of interest to the federal agency or pass-through entity in accordance with that policy. Procurement conflicts are also addressed in section 200.318.

Prior Approval Requirements

Section 200.407 identifies costs and actions that may require prior written approval. The approved budget, agency implementation, and award terms determine what applies to a particular award. Common areas to check include:

• Budget revisions exceeding certain thresholds
• Changes in scope or objectives
• Pre-award costs and timing
• No-cost extensions beyond the first
• Transfer of funds between cost categories beyond the threshold specified in the award

Which Awards Use the 2024 Revision?

OMB made the revision effective October 1, 2024. The final rule also allowed federal agencies to apply it to awards issued before that date, but did not require them to do so. For an older or amended award, check the Notice of Award, agency implementation, and incorporated terms before changing the accounting treatment.

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The Most Common 2 CFR 200 Compliance Mistakes

These are recurring control failures to test before an audit or monitoring visit:

1. Inadequate Time and Effort Documentation

Salary costs are usually the largest single expense on a federal grant, and they require documentation showing that employees worked the percentage of time charged to the grant. Many organizations still use systems that don't meet the UG's standards. The 2024 UG allows more flexibility in how you document effort (moving away from the old semi-annual certification model), but you still need a system that produces reliable results. See our effort reporting guide.

2. Procurement Violations

The most common procurement findings involve:

• Failure to document the basis for contractor selection
• Splitting purchases to avoid competitive bidding thresholds
• Using geographic preferences (prohibited for federal funds)
• Inadequate conflict of interest screening for procurement officials

3. Charging Costs to the Wrong Period

Costs must be incurred during the period of performance to be charged to a federal award. Pre-award costs require the applicable authority and remain at the recipient's risk; costs incurred after the period ends are not newly obligable merely because funds remain. This becomes important when obligations span the award end date.

4. Inadequate Subrecipient Monitoring

Pass-through entities are responsible for monitoring their subrecipients, and many organizations treat this as a paperwork exercise rather than substantive oversight. The UG requires risk assessments, monitoring activities calibrated to risk, and timely corrective action when problems are identified.

5. Mixing Supplanting and Supplementing

Some federal programs require that grant funds supplement, not supplant, existing spending. This means you can't use federal money to pay for something you were already funding with your own resources. Getting this wrong can result in the entire amount being disallowed. See our supplement not supplant guide for program-specific tests.

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How to Stay Current with the Uniform Guidance

The official, current text of 2 CFR 200 is available at ecfr.gov. Bookmark this URL. Don't rely on summary documents, training slides, or unofficial guides as your primary reference. The regulation itself is the definitive source.

OMB periodically issues guidance through memoranda, which are available at the OMB website. These memoranda can modify how the UG is applied even before formal regulatory changes are published.

Your federal awarding agency's grants policy office is another critical resource. Agencies like NIH, NSF, DOE, and ED publish agency-specific guidance that interprets the UG for their programs. These documents address edge cases that the UG itself doesn't cover.

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Where the Uniform Guidance Still Creates Work

One rule set is easier to search than eight circulars, but applying it still requires award-level judgment.

The regulation is still too long. At roughly 150 pages of regulatory text plus appendices, the UG is intimidating for small organizations that may not have dedicated compliance staff. The COFAR (Council on Financial Assistance Reform) promised a simpler regulation, and while the consolidation helped, the result is still dense.

Threshold updates addressed inflation concerns. The 2024 revision raised the equipment threshold from $5,000 to $10,000, the first increase since the UG was published in 2014. This means fewer routine purchases now cross the equipment threshold, reducing the inventory tracking, federal interest provisions, and disposition requirements that were disproportionate to many items' value.

The de minimis rate is an election, not proof of full cost recovery. Compare the elected rate with your actual indirect-cost pool and MTDC base before deciding whether to pursue a negotiated rate.

Pass-through entity requirements don't account for capacity. A small community organization that receives a federal grant and subawards $50,000 to a partner faces the same monitoring requirements as a state agency passing through $50 million in FY2025. The UG could do more to scale requirements based on risk and capacity rather than imposing a one-size-fits-all framework.

Cost-transfer control: When an expense moves between awards, retain the original transaction, the reason for the correction, the allowability and allocability analysis, the approvals, and the posting date. A journal entry without that evidence makes it harder to show that the corrected charge meets sections 200.403 through 200.405.

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Building a Compliance Framework Around 2 CFR 200

If you're starting from scratch or revising your compliance program, use this order:

1. Read the regulation. Not a summary. The actual text at ecfr.gov. Print Subparts D and E.

1. Map your policies to UG sections. Create a crosswalk between your internal policies and the specific UG sections they address. If there's a UG requirement without a corresponding policy, that's a gap you need to fill.

1. Update your financial management system. Make sure your accounting system can segregate federal funds by award, track spending by budget category, and produce reports that match your federal financial reports.

1. Train your staff. Not just the grants office. Train principal investigators, department administrators, and anyone who approves or initiates expenditures on federal awards. They need to understand at least the basics of allowability and documentation.

1. Build monitoring into your routine. Don't wait for the audit. Review expenditures monthly, reconcile drawdowns quarterly, and conduct internal compliance reviews at least annually.

1. Document everything. The UG's documentation requirements are pervasive. If you can't prove you did something, you might as well not have done it. File structures, naming conventions, and record retention schedules should be established upfront.

When this page overlaps with a live opportunity, pair the rule check with allowable costs, procurement standards, Single Audit planning, the grant reports index, and the broader federal grants guide. The regulation tells you the rule; the opportunity file tells you the stricter award condition.

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Related Guides

• Time And Effort Reporting Federal Grants

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Sources

• 2 CFR Part 200, eCFR (current text)
• OMB Office of Federal Financial Management
• Federal Register: 2024 Revisions to 2 CFR 200 (Final Rule)
• OMB Compliance Supplement
• Federal Audit Clearinghouse
• Government Accountability Office, "Standards for Internal Control in the Federal Government" (Green Book)
• Council on Financial Assistance Reform (COFAR), Frequently Asked Questions