Single Audit Threshold: $1,000,000, Up From $750,000

Full answer: The Single Audit threshold is $1,000,000 in federal awards expended for fiscal years beginning on or after October 1, 2024, and $750,000 for earlier years. A calendar 2024 audit period still uses $750,000. Under 2 CFR 200.501, the test uses applicable federal expenditures across the fiscal year, not the face value of one award. An entity below its applicable threshold is exempt from the federal audit requirement for that year, but its records remain available for federal, pass-through, and GAO review.

This guide is for nonprofit finance leaders, state and local government staff, tribal governments, higher-education administrators, pass-through entities, and grants teams deciding whether an audit is required and what file to build next.

Single Audit Threshold 2026: $1 Million Under 2 CFR 200.501

Data note: Source review by Grantsights checked the current eCFR text for 2 CFR 200.501, 2 CFR 200.502, 2 CFR 200.511, 2 CFR 200.512, 2 CFR 200.518, the Federal Audit Clearinghouse threshold guidance, and OMB's 2024 final guidance on September 13, 2026.

If you are checking the current Single Audit threshold, answer two questions in order: when did the audit period begin, and how much applicable federal award funding was expended during that period?

This date split is why a generic answer such as “the 2025 threshold” can be wrong. The fiscal-year start date controls the transition.

Threshold-to-FAC Filing Clock

The threshold decision and filing deadline use different dates. Determine the applicable threshold from the start of the audit period. If an audit is required, 2 CFR 200.512 makes the reporting package due by the earlier of two dates: 30 calendar days after the auditee receives the auditor's report, or nine months after the audit period ends.

Download the Single Audit threshold and filing checklist (CSV) to calculate the controlling threshold, record the expenditure units, and track both filing deadlines. Confirm the final deadline with the current rule and FAC instructions.

If the expenditure file contains charges that have not passed the general cost principles, use the allowable costs guide to resolve classification, allocability, reasonableness, policy, and approval evidence before finalizing the SEFA.

What 2 CFR 200.501 Doesn't Tell You

The official rule tells you when an audit is required. It does not decide whether your finance file is ready for the audit, whether your pass-through awards are classified correctly, or whether your organization should fix SEFA issues before the auditor arrives.

Based on our analysis of the rule text, FAC instructions, and the query variants bringing readers to this page, the recurring gap is a two-part test: fiscal-year start date first, federal awards expended second. The wrong route is using the year printed on an audit, the award face value, or cash draws as the threshold test.

For example, one nonprofit with a July 1, 2024 fiscal-year start and $900,000 in applicable federal expenditures crosses the $750,000 threshold. If the same organization starts its next fiscal year on July 1, 2025 and expends the same $900,000, it remains below the $1,000,000 threshold. The expenditure amount did not change, but the audit decision did.

A separate example shows why award value is not enough: a nonprofit can receive a $1,200,000 federal award and remain below the audit threshold in year one if its applicable federal expenditures are only $650,000 during that fiscal year. It can cross the threshold later when additional allowable costs or subawards meet the expenditure rules in 2 CFR 200.502.

Use the threshold as a route decision:

For the file build, pair this threshold screen with the grant audit preparation guide, grant records retention guide, subrecipient monitoring guide, federal grant compliance requirements, and grant-ready organization guide. If the audit cost changes whether a federal award is still worth pursuing, compare open opportunities in the grant database.

This guide separates the legal threshold decision from SEFA preparation, major-program selection, findings, corrective action, and FAC submission. Use a qualified auditor and your federal oversight or cognizant agency for advice about a specific audit.

Last updated: September 13, 2026

Related Guides

• Grant Audit Preparation
• 2 CFR 200 Uniform Guidance
• Grant Records Retention

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What Is a Single Audit?

A single audit, formerly known as an A-133 audit (after the OMB Circular it replaced), is a 2-part, organization-wide audit of an entity's federal award expenditures. It's called "single" because one audit covers all federal programs simultaneously, rather than each federal agency auditing its own awards separately.

The single audit has two components:

1. Financial statement audit: Standard audit of the organization's financial statements under Generally Accepted Auditing Standards (GAAS)
2. Federal awards audit: Compliance testing of major federal programs under Government Auditing Standards and the Compliance Supplement

The legal authority comes from the Single Audit Act of 1984 (as amended in 1996) and its implementing regulations in 2 CFR 200 Subpart F.

Who Needs a Single Audit?

The $1,000,000 Threshold

Under 2 CFR 200.501, a non-federal entity that expends $1,000,000 or more in federal awards during a fiscal year beginning on or after October 1, 2024 must have a single audit or permitted program-specific audit. For audit periods beginning before October 1, 2024, FAC says to apply the prior $750,000 threshold.

"Non-federal entity" includes:

• State and local governments
• Tribal governments
• Nonprofit organizations
• Institutions of higher education

What counts toward the threshold:

• Direct federal awards you spend during the year
• Federal funds received as a subrecipient (pass-through funds)
• Federal funds you pass through to subrecipients
• Loan and loan guarantee programs (the amount of new loans during the year)

What doesn't count:

• Non-federal awards (state, local, private)
• Federal awards received but not yet expended
• Procurement contracts from federal agencies (you're a vendor, not a recipient)

Common Threshold Scenarios

Organizations Approaching the Threshold

If applicable expenditures are approaching the threshold, build and reconcile the SEFA before year-end. Do not change legitimate program timing to avoid an audit. Use the audit-period start date and the expenditure rules in 2 CFR 200.502 to make the threshold decision, then obtain engagement-specific pricing from qualified auditors if an audit is required.

For a deeper understanding of the regulations, see our 2 CFR 200 Uniform Guidance guide.

The Schedule of Expenditures of Federal Awards (SEFA)

The SEFA is the 9-field starting file for a single audit. It drives which programs get audited, how auditors assess risk, and whether the reported expenditure population is complete.

SEFA Components

Your SEFA must include, for each federal program:

SEFA Preparation Best Practices

Maintain the SEFA year-round. Treating the SEFA as a year-end-only exercise can leave too little time to resolve award, ALN, pass-through, or expenditure mismatches. Update it on a defined cadence and complete a final reconciliation after year-end.

Reconcile to three sources:

1. Your general ledger (expenditures posted to federal award accounts)
2. Federal drawdown reports (from PMS, ASAP, or agency-specific systems)
3. Award documents (notice of award, budget, and any modifications)

If these three numbers don't agree, you have a problem that needs resolution before the auditor arrives.

Verify ALN numbers. The Assistance Listing (formerly CFDA) number is how auditors identify your programs and determine the applicable compliance requirements from the Compliance Supplement. A wrong ALN number can cause auditors to test the wrong compliance requirements or miss a major program entirely.

Track subrecipient expenditures separately. If you pass federal funds to subrecipients, those amounts must be reported on your SEFA even though the subrecipient spent the money. This is one of the most commonly missed items.

Major Program Determination

The auditor doesn't test every federal program. They apply the 3-step risk-based process in 2 CFR 200.518 to identify Type A and Type B programs, assess risk, and select major programs.

Use the grant audit preparation guide to turn the auditor's major-program selection into a program-by-program evidence request before fieldwork begins.

Step 1: Identify Type A and Type B Programs

Type A programs use the current 2 CFR 200.518 table. For entities expending at least $1,000,000 but less than $34 million in federal awards, the Type A threshold is $1,000,000. Higher-expenditure bands use the other current table thresholds, so do not carry forward the pre-2024 $750,000 or percentage shortcut.

All other programs are Type B.

Step 2: Assess Risk

For Type A programs, the auditor assesses whether each program is low-risk or high-risk based on:

• Prior audit findings (findings in the past two years = high risk)
• Internal control weaknesses
• Whether the program was audited as major in the prior two years
• Changes in program personnel, systems, or regulations
• Complexity of the compliance requirements

Step 3: Select Major Programs

• All high-risk Type A programs must be tested as major programs
• Low-risk Type A programs may be excluded
• The auditor selects high-risk Type B programs to test
• At least 40% of total federal expenditures must be covered (20% for low-risk auditees)

Low-Risk Auditee Status

Your organization qualifies as a low-risk auditee if:

• Single audits were performed in the two prior years
• Auditor's opinions were unmodified in both years
• No material weaknesses in internal controls
• No going concern issues
• No major programs with questioned costs exceeding 5% of expenditures

Low-risk status reduces the percentage coverage requirement from 40% to 20% and makes the audit process generally less intensive.

The 12 Compliance Requirement Types

The current OMB Compliance Supplement describes 12 active compliance requirement types. Auditors use the program matrix and professional judgment to determine which marked requirements apply and could have a direct and material effect on a major program.

Not all 12 requirements apply to every program. Check the current OMB Compliance Supplement matrix and the program-specific section rather than copying a generic list into the audit file.

Common Single Audit Findings

The OMB Compliance Supplement and FAC records organize the evidence behind recurring audit issues. Use these categories as a file-review screen, not as a claim that every program tests every category:

Evidence Risks by Category

Material Weakness vs. Significant Deficiency

Auditors classify internal control findings as either:

• Material weakness: A deficiency, or combination of deficiencies, where there is a reasonable possibility that a material non-compliance will not be prevented or detected and corrected in a timely manner
• Significant deficiency: A deficiency that is less severe than a material weakness but important enough to merit attention

Material weaknesses are serious and may trigger federal agency intervention. Significant deficiencies require corrective action but don't typically trigger immediate consequences beyond the corrective action plan.

Corrective Action Plans

When a single audit identifies findings, 2 CFR 200.511 requires the auditee to prepare a corrective action plan for each current-year finding. Use the 6-element file below to make the response specific and assignable. The plan is submitted with the reporting package by the deadline in 2 CFR 200.512.

What a Good CAP Includes

For each finding:

1. Reference to the finding number from the audit report
2. Management's response: Do you agree or disagree with the finding? (Disagreements must include the basis for disagreement)
3. Planned corrective action: Specific steps to resolve the issue
4. Responsible person: Name and title of the person who will implement the correction
5. Anticipated completion date: Realistic timeline for resolution
6. Status of prior year findings: If this is a repeat finding, explain why the prior CAP didn't work

CAP Mistakes to Avoid

Don't be vague. "We will improve our processes" is not a corrective action plan. Specify what process will change, who will change it, and by when.

Don't disagree without strong evidence. Management disagreements with audit findings are reviewed by federal agencies. If you disagree, you need specific regulatory citations or documentation supporting your position.

Don't ignore repeat findings. A finding that appears in consecutive audits signals to federal agencies that you can't manage their money. Repeat findings can lead to specific award conditions, additional monitoring, or even suspension.

Federal Audit Clearinghouse (FAC)

All single audit reports must be submitted to the Federal Audit Clearinghouse within the earlier of:

• 30 calendar days after receipt of the auditor's report, or
• Nine months after the end of the audit period

Submit through FAC.gov. The submission includes:

• Data Collection Form (SF-SAC)
• Single audit reporting package (auditor's reports, financial statements, SEFA, findings, corrective action plans)

Federal awarding agencies and pass-through entities access the FAC to review audit results for their recipients. Late submissions can trigger funding holds.

For more on post-award requirements, see our grant closeout checklist guide.

Selecting an Auditor

Not any CPA firm can perform a single audit. Use a 4-part screen covering qualifications, independence, relevant federal-award experience, and engagement delivery. Requirements include:

Auditor Qualifications

• Must meet Government Auditing Standards (Yellow Book) requirements
• Must satisfy the independence and licensing requirements that apply to the engagement
• Should provide current peer-review information required by the applicable audit standards
• Should have experience with your type of organization and federal programs

What to Look for in a Single Audit Firm

• Federal awards experience: How many single audits do they perform annually?
• Industry expertise: Do they audit organizations like yours (universities, nonprofits, governments)?
• Compliance Supplement knowledge: Are they current on the latest supplement?
• Peer review results: Request their most recent peer review report
• Staff continuity: Will the same team work on your audit year after year?

Four File-Building Lessons From the Rule Set

The SEFA controls the starting point. Auditors use the SEFA to identify federal programs and begin major-program determination. Reconcile it to the general ledger, award records, pass-through information, and the expenditure rules before fieldwork.

Subrecipient monitoring needs a complete evidence chain. If you pass federal funds to subrecipients, 2 CFR 200.332 requires risk evaluation, monitoring, audit follow-up when applicable, and management decisions on relevant findings. Keep the subaward terms, risk screen, monitoring record, and follow-up together.

Auditor communication does not replace auditee ownership. Agree on the information request, due dates, and issue-resolution process while preserving the independence requirements that apply to the engagement. Management remains responsible for the financial statements, SEFA, and representations it provides.

Prior year findings get extra scrutiny. Auditors are required to follow up on prior year findings. If a finding repeats, it signals a systemic problem. Federal agencies may impose specific conditions on your awards. Address findings completely the first time, even if it means investing in new systems or staff. See our federal grant compliance requirements guide for more on staying in compliance.

Event-Based Single Audit Timeline

Sources

• 2 CFR 200 Subpart F - Audit Requirements
• Federal Audit Clearinghouse
• FAC threshold guidance
• 2 CFR 200.511 Audit findings follow-up
• 2 CFR 200.512 Report submission
• 2 CFR 200.518 Major program determination
• OMB 2024 final guidance
• OMB Compliance Supplement
• Government Auditing Standards (Yellow Book)
• AICPA Single Audit Resources
• 2 CFR 200.501 Audit Requirements