Grant Compliance Checklist for Nonprofits
Stay compliant with your grants using this comprehensive checklist covering documentation, allowable costs, reporting, and federal requirements.
On this page
- Pre-Award Compliance
- Financial Management
- Documentation Requirements
- Federal Grant Requirements
- Reporting Compliance
- Property and Equipment
- Subrecipient Management
- Record Retention
- Audit Preparation
- Internal Controls
- Example Internal Compliance Calendar
- Common Compliance Pitfalls
- How GrantLink supports this today
Showing the main sections of 49 total headings.
Grant compliance isn't just about avoiding audit findings—it's about being a trustworthy steward of funder resources. This checklist covers the key compliance areas every grant-funded nonprofit should address.
Pre-Award Compliance
Before accepting a grant, ensure you can comply:
Organizational Readiness
- Financial systems adequate for grant tracking
- Staff capacity to manage the grant
- Policies in place (procurement, travel, personnel)
- Insurance coverage meets requirements
- Registration current (SAM.gov for federal, state registrations)
Grant Agreement Review
- Terms understood by all relevant staff
- Budget is realistic and complete
- Match requirements can be met (if applicable)
- Reporting deadlines are calendared
- Restrictions are understood and acceptable
- Prior approval requirements identified
Financial Management
Cost Principles (2 CFR 200 for Federal)
All costs charged to grants must be:
- Allowable — Permitted under grant terms and regulations
- Allocable — Benefit the grant proportionally to the charge
- Reasonable — What a prudent person would pay
- Consistent — Treated the same across grants
Allowable vs. Unallowable Costs
Generally Allowable:
- Salaries and wages (with documentation)
- Fringe benefits
- Travel (per policy and grant limits)
- Supplies directly used for grant
- Contractual services (with proper procurement)
- Indirect costs (per rate agreement)
Commonly unallowable or restricted under federal rules: Exceptions, credits, and award-specific provisions can change the conclusion; review the applicable cost principle.
- Entertainment
- Alcohol
- Lobbying
- Fundraising
- Fines and penalties
- Bad debts
- Contingency provisions
- General advertising
- Goods/services for personal use
Budget Management
- Budget approved before spending
- Spending within categories (or approval for changes)
- No overspending total award
- Prior approval obtained for budget changes (if required)
- Cost transfers are timely, justified, documented
Documentation Requirements
General Documentation
Every expense needs:
- Source support — Invoice, receipt, payroll record, agreement, or other evidence appropriate to the transaction
- Posting and payment evidence — As applicable to the accounting basis and report being supported
- Purpose documentation — Why the expense was needed
- Grant coding — Which grant is charged
- Approval — Appropriate authorization
Personnel Documentation
- Personnel records and controls appropriate to the organization and award; a timesheet is not universally required
- Payroll support accurately reflects work performed and meets award and internal-control requirements; federal rules do not universally mandate semiannual certifications
- Position descriptions match actual duties
- Effort reporting matches charges
- Salary reasonableness documentation
Travel Documentation
- Prior approval (if required)
- Business purpose documented
- Receipts or other support retained as required by policy, award terms, and the nature of the cost
- Travel policy and award limits followed; 2 CFR 200.475 does not universally require recipients to use federal per diem rates
- Mileage or equivalent support retained when required by the reimbursement method and policy
- Comparison to alternatives (if required)
Procurement Documentation
For each purchase, apply the documentation appropriate to the procurement method and the organization's documented thresholds. Not every item below is required for every purchase:
- Competition documented (quotes, bids)
- Selection rationale explained
- Conflict of interest certification
- Contract or purchase order
- Price reasonableness analysis
Federal Grant Requirements
If you receive federal funds (directly or as pass-through):
Uniform Guidance (2 CFR 200)
- Written policies addressing:
- Allowable costs
- Cash management
- Conflict of interest
- Procurement
- Travel
- Indirect cost rate documented
- Property management procedures
- Subrecipient monitoring (if you make subawards)
Certifications and Representations When Applicable
- Lobbying certification or disclosure required by the transaction and applicable rule
- Suspension/debarment representations or checks required for the covered transaction
- Drug-free workplace requirements applicable to the recipient and award
SAM.gov Registration
- Registration current (must renew annually)
- UEI number obtained
- Banking information current
Reporting Compliance
Financial Reporting
- SF-425 or other financial report submitted on time when required by the award or agency
- Reports match general ledger
- Cash draws reconciled to expenditures
- Budget-to-actual variances explained
Programmatic Reporting
- Progress reports submitted by deadline
- Outcomes data accurate and verified
- Activities documented throughout the period
- Photos/evidence collected as required
Timely Submission
| Report Type | Typical Deadline |
|---|---|
| Quarterly financial | Per award; many federal periodic reports allow 30 days after the period |
| Progress reports | Per agreement |
| Annual reports | Per agreement |
| Federal closeout | Generally 120 days for recipients and 90 days for subrecipients; agreement controls other reports |
Property and Equipment
Tracking Requirements
- Inventory system for equipment meeting the applicable definition and award terms (the federal equipment threshold is currently $10,000 per unit, unless the recipient uses a lower capitalization level)
- Tags or labels used when required by the organization's control system, award terms, or applicable law
- Physical inventory conducted and reconciled at least once every two years when 2 CFR 200.313(d)(2) applies
- Location of equipment documented
Disposition
When grant ends:
- Disposition instructions requested when required by the award or 2 CFR 200.313(e); do not assume every item requires written approval
- Fair market value obtained if sold
- Proceeds handled per grant terms
- Documentation of disposition
Subrecipient Management
If you make subawards:
Pre-Award
- Risk assessment conducted
- Award document includes required terms
- Assistance Listings number and other required federal award identification passed through
- Indirect cost rate documented
During Award
- Monitoring plan implemented
- Financial reports reviewed
- Technical reports reviewed
- Site visits conducted (if required)
- Issues addressed promptly
Closeout
- Final reports collected
- Expenditures reconciled
- Audit status verified
Record Retention
Federal Grants
Retain records generally for 3 years from submission of the final financial report under 2 CFR 200.334, subject to its different rule for quarterly/annual renewals and listed exceptions, including:
- Litigation or audit pending
- Records relate to real property or equipment
All Grants
Keep:
- Grant agreements and amendments
- All financial records
- Supporting documentation
- Reports (all versions)
- Correspondence
- Audit workpapers
Audit Preparation
Annual Preparation
- Reconcile all grant accounts
- Review for compliance issues
- Prepare supporting schedules
- Organize documentation
Single Audit (generally if $1,000,000+ in federal awards is expended in the fiscal year)
- SEFA prepared accurately
- Major programs identified
- PBC list items prepared
- Prior findings addressed
Internal Controls
Segregation of Duties
- Authorization separated from recording
- Custody separated from recording
- Reconciliation by independent party
Approval Requirements
- Expense approval thresholds defined
- Journal entry approval required
- Budget change approval process
- Signature authority documented
Optional Internal Review Processes
- Grant budget review cadence defined based on reporting deadlines, risk, and transaction volume
- Compliance review cadence defined based on award requirements and risk
- Policy review triggers include regulatory, award, system, and organizational changes
Example Internal Compliance Calendar
The following is a planning template, not a federal schedule. Replace each cadence with the award's actual deadlines and the organization's risk-based controls.
Monthly
- Reconcile grant expenses
- Review budget vs. actual
- Enter all transactions
- Update encumbrances
Quarterly
- Submit required reports
- Review compliance status
- Document grant activity
- Update risk assessments
Annually
- Update policies as needed
- Renew registrations (SAM.gov)
- Audit preparation
- Staff training refresh
At Grant End
- Final financial reconciliation
- Final reports submitted
- Property disposition
- Records organized for retention
Common Compliance Pitfalls
Documentation Gaps
Problem: Can't support charges Prevention: Document at time of transaction
Cost Transfers
Problem: Moving costs to avoid deficits Prevention: Charge correctly initially, justify any transfers
Time Reporting
Problem: Payroll charges are not supported by records that accurately reflect work performed, or interim estimates are not reviewed and adjusted Prevention: Operate a documented personnel-cost control system that meets the award and applicable rules
Procurement Shortcuts
Problem: Skipping competition requirements Prevention: Follow policy regardless of urgency
Missed Deadlines
Problem: Late reports Prevention: Calendar and reminders
How GrantLink supports this today
GrantLink helps by organizing allocations backed by QuickBooks Online, budget lines, fund receipts, funding shares, documents, report outputs, and activity history. It supports audit preparation, but it does not replace funder guidance, accounting policy, or professional review.
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