Uniform Guidance 2024+ Update for Nonprofits

OMB published a revision of the Uniform Guidance (2 CFR Part 200) on April 22, 2024, and the revised text took effect on October 1, 2024. The eCFR shows no later amendments to Part 200, so the 2024 text is the current rule, and the article below describes it.

Status of the 2026 proposed rewrite

On May 29, 2026, OMB and other federal agencies published a proposed rule titled "Regulation for Federal Financial Assistance," which would rewrite Part 200. It is a proposal, so it does not change any requirement yet. Section 157 of the Continuing Appropriations and Extensions Act, 2027 (Public Law 119-103, signed September 2, 2026) bars OMB from issuing or finalizing that rule, or a substantially similar rule, through December 11, 2026.

Executive Order 14332, "Improving Oversight of Federal Grantmaking" (August 7, 2025), directed OMB to revise the Uniform Guidance and directed agencies to review their grant terms, including termination terms. The order does not change the text of Part 200 by itself, so read the terms of each new award and amendment.

Effective date

The 2024 revisions took effect on October 1, 2024, and they generally apply to federal awards issued on or after that date. They do not automatically change an older award, although an agency can apply them through an amendment or a later funding action. The audit changes, including the Single Audit threshold, apply to fiscal years that begin on or after October 1, 2024. Check how your agency implemented the changes and which terms your award includes.

What changed

Topic	Before October 1, 2024	Current rule
Single Audit threshold	$750,000 in federal expenditures	$1,000,000 in federal expenditures
Subawards in MTDC	First $25,000 of each subaward	First $50,000 of each subaward, regardless of the subaward's period of performance
De minimis indirect cost rate	10% of MTDC	Up to 15% of MTDC
Equipment threshold	$5,000 per unit	Lesser of the recipient's capitalization level or $10,000 per unit, with a useful life of more than one year

A recipient or subrecipient that does not have a current federally negotiated indirect cost rate, including a provisional rate, may elect a de minimis rate of up to 15% of MTDC. It does not need agency approval or documentation to justify the rate. The election is not limited to organizations that never had a negotiated rate. Once an organization elects the rate, it must use it for all federal awards until it chooses to negotiate a rate. A federal statute or regulation can limit the election, and the rate does not apply to cost-reimbursement contracts that the federal government issues directly under the FAR. See 2 CFR 200.414(f).

Other rules that are often misstated

• Participant support costs are direct costs for participants or trainees, not employees, e.g., stipends, subsistence allowances, travel allowances, registration fees, and temporary dependent care. They are excluded from MTDC. The current 2 CFR 200.456 no longer requires prior approval to charge them, but your written policies must define what counts as participant support, and you must apply that definition the same way on every federal award. Under 2 CFR 200.308(f)(5), you still need prior approval to move funds budgeted for participant support costs to other budget categories. Do not call staff pay participant support.
• The 2024 revision removed several prior approval requirements, but prior approval still exists. Examples include unrecovered indirect costs counted as cost sharing, changes in scope or key personnel, changes in the approved cost sharing amount, and the capital expenditures listed in 2 CFR 200.439. Check the award and the agency's rules.
• For procurement, Part 200 uses the micro-purchase threshold and simplified acquisition threshold defined in the FAR instead of fixed dollar amounts. GSA reports that the FAR raised these thresholds to $15,000 and $350,000 on October 1, 2025. Your documented threshold can be lower, and 2 CFR 200.320 lets you self-certify a micro-purchase threshold of up to $50,000 if you meet its conditions. Follow 2 CFR 200.320, GSA's threshold table, state and local law, your own policy, and the strictest term that applies.
• The general record retention period is three years from the date you submit the final financial report. It does not start at the purchase date or the award end date. Litigation, claims, audits, property and equipment records, and some other cases change the start date or extend the period. See 2 CFR 200.334.
• For personnel costs, 2 CFR 200.430 requires records that accurately reflect the work performed and that are supported by internal controls. It does not require one specific timesheet, signature, monthly activity report, semiannual certification, or quarterly reconciliation for everyone.
• You decide case by case whether an organization is a subrecipient or a contractor, based on the substance of the relationship under 2 CFR 200.331. Under 2 CFR 200.332, a pass-through entity must give each subrecipient the required award information, evaluate its risk, review its reports, follow up on problems, and issue management decisions on audit findings about its subaward. Site visits and fixed monitoring schedules are optional tools that you choose based on risk.
• Federal agencies do not expect voluntary committed cost sharing on research grants, and they are discouraged from using it in merit review for other programs. If you include it in the approved budget, it becomes binding. Cost sharing you count must meet 2 CFR 200.306, and unrecovered indirect costs need prior approval before you count them.

What to review now

1. Review the indirect cost assumptions on your active federal grants.
2. Update your internal policies and audit preparation checklists.
3. Confirm that your reporting and monitoring workflows use the current thresholds.

Notes

• Award terms can be stricter than the federal defaults.
• A state agency or other pass-through entity may add requirements.
• Your accountant and auditor should confirm the final treatment.
• The agency's implementation and each award's terms decide whether a 2024 change applies to an older award.
• Start from the 2024 final guidance in the Federal Register, its official PDF, and the current 2 CFR Part 200. Do not treat the 2026 proposed rule as final.