Grant Compliance Checklist for Nonprofits
Use this checklist to cover documentation, allowable costs, reporting, property, subawards, and federal requirements for your grants.
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On this page
- Before you accept an award
- Financial management
- Documentation
- Federal requirements
- Reporting
- Property and equipment
- Subrecipient management
- Record retention
- Audit preparation
- Internal controls
- Example internal compliance calendar
- Common compliance problems
- How GrantLink supports this today
Showing the main sections of 44 total headings.
Grant compliance means you use funds as the award allows and you can prove it with records. This checklist covers the main compliance areas for a nonprofit that receives grants. Federal items apply to federal awards, including federal funds you receive through a pass-through entity.
Federal citations refer to the 2024 revision of 2 CFR 200, which took effect on October 1, 2024. OMB published a proposed revision on May 29, 2026. As of October 2026, no final rule is in effect.
Before you accept an award
Make sure you can comply before you accept a grant.
Organizational readiness
- Your financial system can track spending by grant.
- You have staff capacity to manage the grant.
- Your policies are in place, e.g., procurement, travel, and personnel.
- Your insurance meets the award's requirements.
- Your registrations are current, e.g., SAM.gov for federal awards and any state charity registrations.
Award review
- All relevant staff understand the terms.
- The budget is realistic and complete.
- You can meet any match requirement.
- Reporting deadlines are on the calendar.
- You understand and accept the restrictions.
- You have identified the changes that need prior approval.
Financial management
Cost principles (2 CFR 200 for federal awards)
Each cost you charge to a federal award must meet these tests under 2 CFR 200.403 to 200.405:
- Allowable. The award terms and the cost principles permit it.
- Allocable. The grant benefits in proportion to the charge.
- Reasonable. A prudent person would pay the same amount in the same situation.
- Consistent. You treat the same type of cost the same way, as direct or indirect, across all activities.
Allowable and unallowable costs
Costs that are generally allowable when they meet the tests above:
- Salaries and wages, with records of the work performed
- Fringe benefits
- Travel, under your policy and the award limits
- Supplies used for the grant
- Contract services, bought under proper procurement
- Indirect costs, under your rate agreement or the de minimis rate
Costs that are often unallowable or restricted under the federal cost principles are listed below. Exceptions, credits, and award terms can change the answer, so review the specific cost section:
- Entertainment
- Alcoholic beverages
- Lobbying
- Fundraising
- Fines and penalties
- Bad debts
- Contingency provisions
- Advertising that isn't one of the allowed purposes
- Goods or services for personal use
Budget management
- The budget was approved before you spent funds.
- Spending stays within budget categories, or you have approval for changes when the award requires it.
- Total spending stays within the award.
- You got prior approval for budget changes that need it.
- Cost transfers are timely, justified, and documented.
Documentation
General documentation
Every expense needs:
- Source support that fits the transaction, e.g., an invoice, receipt, payroll record, or agreement
- Evidence that the expense was posted and paid, as the accounting basis and report require
- The reason the expense was needed
- Grant coding that shows which grant pays for it
- Approval by an authorized person
Personnel documentation
- Personnel records and controls that fit your organization and the award. A timesheet is not required in every case.
- Payroll support that accurately reflects the work performed, under 2 CFR 200.430(g). Federal rules don't require semiannual certifications in every case.
- Position descriptions that match the actual duties
- Records of effort that match the charges
- Support that salaries are reasonable
Travel documentation
- Prior approval, if the award requires it
- A documented business purpose
- Receipts or other support, as your policy, the award, and the type of cost require
- Compliance with your travel policy and the award limits. 2 CFR 200.475 doesn't require every recipient to use federal per diem rates.
- Mileage records or similar support, when your reimbursement method needs them
- A comparison to other options, if required
Procurement documentation
For each purchase, keep the records that fit the procurement method and your documented thresholds. Not every item below applies to every purchase:
- Evidence of competition, e.g., quotes or bids
- The reason you chose the vendor
- Conflict of interest disclosures
- A contract or purchase order
- An analysis showing the price is reasonable
Under 2 CFR 200.1, the federal micro-purchase and simplified acquisition thresholds follow the FAR. Since October 1, 2025, FAR 2.101 sets them at $15,000 and $350,000. Your own thresholds may be lower, based on your documented procedures and risk.
Federal requirements
The items below apply if you receive federal funds directly or through a pass-through entity.
Uniform Guidance (2 CFR 200)
- Written procedures for deciding whether costs are allowable and for cash management, under 2 CFR 200.302(b)
- Written procurement procedures and conflict of interest standards, under 2 CFR 200.318
- A travel policy, if you charge travel to awards
- A documented indirect cost rate or the de minimis rate election
- Property management procedures
- Subrecipient monitoring, if you make subawards
Certifications and representations, when they apply
- Lobbying certification or disclosure required for the transaction
- Suspension and debarment checks or representations required for the covered transaction
- Drug-free workplace requirements that apply to you and the award
SAM.gov registration
- Your SAM.gov registration is active. Under 2 CFR 25.200, you must review and update your registration at least once a year while you have an active award or pending application.
- You have a Unique Entity Identifier (UEI).
- Your banking information is current.
Reporting
Financial reporting
- You submit the SF-425 or other financial report on time when the award or agency requires it.
- Reports match the general ledger.
- Cash draws are reconciled to spending.
- Budget to actual variances are explained.
Program reporting
- Progress reports are submitted by the deadline.
- Outcome data is accurate and checked.
- Activities are documented throughout the period.
- Photos and other evidence are collected when required.
Typical deadlines
| Report type | Typical deadline |
|---|---|
| Quarterly or semiannual performance report | Per the award. Under 2 CFR 200.329(c), these are due no later than 30 calendar days after the reporting period. |
| Annual performance report | Per the award. Under 200.329(c), annual reports are due no later than 90 calendar days after the reporting period. |
| Financial reports | Per the award and the agency's instructions |
| Federal final reports | 120 calendar days after the period of performance for recipients, and 90 days for subrecipients, under 2 CFR 200.344. The agreement controls other grants. |
Property and equipment
Tracking
- You keep an inventory system for equipment that meets the definition and the award terms. Under 2 CFR 200.1, the federal equipment threshold is $10,000 per unit, or your capitalization level if it is lower.
- You use tags or labels when your controls, the award, or the law require them.
- You take a physical inventory and reconcile it to the property records at least once every two years, when 2 CFR 200.313(d)(2) applies.
- You record where each piece of equipment is.
Disposition
When the equipment is no longer needed:
- Request disposition instructions when the award terms require them, under 2 CFR 200.313(e). Not every item needs written approval.
- Get the fair market value if you sell an item.
- Handle the proceeds under the award terms.
- Document the disposition.
Subrecipient management
If you make subawards, 2 CFR 200.332 applies.
Before the subaward
- Check SAM.gov to confirm the subrecipient isn't excluded.
- Evaluate the subrecipient's risk, under 200.332(c).
- Include the required terms in the subaward document.
- Pass through the Assistance Listing number and other required federal award information.
- Document the subrecipient's indirect cost rate.
During the subaward
- Carry out a monitoring plan, under 200.332(e).
- Review financial reports.
- Review performance reports.
- Conduct site visits, if your risk assessment calls for them.
- Address issues promptly.
At closeout
- Collect final reports.
- Reconcile spending.
- Confirm the subrecipient's audit status.
Record retention
Federal grants
Under 2 CFR 200.334, keep records generally for 3 years from the date you submit the final financial report. Awards renewed quarterly or annually follow a different start date, and the section lists exceptions, including these:
- Litigation, claims, or audits that start before the 3 years end
- Property and equipment records, which you keep for 3 years after final disposition
All grants
Keep:
- Grant agreements and amendments
- All financial records
- Supporting documents
- All versions of reports
- Correspondence
- Audit workpapers
Audit preparation
Each year
- Reconcile all grant accounts.
- Review for compliance issues.
- Prepare supporting schedules.
- Organize documentation.
Single audit
Under 2 CFR 200.501, you generally need a single audit if you spend $1,000,000 or more in federal awards in your fiscal year.
- Prepare the schedule of expenditures of federal awards (SEFA) accurately.
- Know which programs the auditor will test as major programs.
- Prepare the items on the auditor's request list.
- Address prior findings.
Internal controls
Separation of duties
- The person who approves a transaction doesn't record it.
- The person who handles cash or assets doesn't record them.
- Someone independent does the reconciliations.
Approval rules
- Expense approval limits are defined.
- Journal entries need approval.
- Budget changes follow an approval process.
- Signature authority is documented.
Internal review practices
- Set how often you review grant budgets, based on reporting deadlines, risk, and transaction volume.
- Set how often you review compliance, based on award requirements and risk.
- Review policies when regulations, awards, systems, or your organization change.
Example internal compliance calendar
The calendar below is a planning template, not a federal schedule. Replace each item with the award's actual deadlines and your own controls.
Monthly
- Reconcile grant expenses.
- Review budget versus actual.
- Enter all transactions.
- Update encumbrances.
Quarterly
- Submit required reports.
- Review compliance status.
- Document grant activity.
- Update risk assessments.
Annually
- Update policies as needed.
- Review and update your SAM.gov registration.
- Prepare for the audit.
- Refresh staff training.
At the end of each grant
- Complete the final financial reconciliation.
- Submit final reports.
- Dispose of property as required.
- Organize records for retention.
Common compliance problems
| Problem | Prevention |
|---|---|
| You can't support a charge. | Document each cost when it happens. |
| Costs are moved to cover shortfalls. | Charge costs correctly the first time, and justify any transfer. |
| Payroll charges don't match records of the work performed, or nobody reviews and adjusts interim estimates. | Run a documented personnel cost system that meets the award and the rules. |
| Staff skip competition requirements. | Follow your procurement policy, even when a purchase is urgent. |
| Reports are late. | Put deadlines on a calendar and set reminders. |
How GrantLink supports this today
GrantLink keeps grant records next to your QuickBooks data. Each grant has a Budget section, a Transactions section with Allocations, Invoices & receipts, and Funding shares, a Reporting section, and an Activity history. Documents and notes are in the grant's Details section. These records can help you prepare for an audit, but they don't replace the award terms, your accounting policies, or professional review.
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How to Allocate Expenses Across Multiple Grants
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