Uniform Guidance 2024+ Update for Nonprofits

OMB published the 2024 Uniform Guidance rewrite on April 22, 2024. The current eCFR was checked on August 2, 2026 (the eCFR page reported Title 2 current through July 30, 2026). The May 29, 2026 government-wide overhaul is still a proposed rule, not current law; this article therefore describes the current codified Part 200 and applicable 2024 revisions.

Effective Date

The 2024 revisions became effective October 1, 2024 and generally apply to federal awards issued on or after that date. They do not automatically rewrite an older award; an agency may apply them through an amendment or later funding action. Audit changes, including the Single Audit threshold, apply to fiscal years beginning on or after October 1, 2024. Confirm the agency's implementation and the award's incorporated terms.

What Changed

Topic	Previous	Current
Single Audit trigger	$750,000 federal expenditures	$1,000,000 federal expenditures
MTDC subaward inclusion	First $25,000 per subaward	Up to first $50,000 of each subaward, regardless of period of performance
De minimis indirect rate	10% MTDC	15% MTDC
Federal equipment ceiling	$5,000 per unit	Lesser of recipient capitalization level or $10,000 per unit, with useful life over one year

An eligible recipient or subrecipient without a current federally negotiated indirect cost rate may elect a rate of up to 15% of MTDC without prior agency approval. Applicable federal statute or regulation can limit the election, and it does not apply to direct federal cost-reimbursement contracts governed by the FAR. It is not limited to organizations that have never had a negotiated rate. See 2 CFR 200.414(f).

Other Frequently Misstated Rules

• Participant support: Participant support costs are direct costs for participants or trainees—not employees—such as stipends, subsistence, travel allowances, registration fees, and certain temporary dependent-care costs. They are excluded from MTDC. The 2024 rewrite removed the government-wide prior-approval requirement formerly in 2 CFR 200.456, but the award, agency, or a budget revision under 2 CFR 200.308 may still require approval. Do not call staff compensation participant support.
• Prior approval: The rewrite removed several government-wide prior-approval requirements, but did not eliminate prior approval generally. Examples that remain include unrecovered indirect costs used as cost share, certain budget or program-plan revisions, and capital expenditures specified in 2 CFR 200.439. Check the award and agency rules.
• Procurement: Part 200 uses the FAR-defined micro-purchase threshold and simplified acquisition threshold rather than fixing all dollar amounts in the text. Effective October 1, 2025, the general FAR thresholds increased to $15,000 and $350,000, respectively; special lower and higher thresholds exist, and a recipient's documented threshold may be lower or, when 2 CFR 200.320 permits, higher. Follow 2 CFR 200.320, GSA's current threshold table, state/local law, organizational policy, and the most restrictive applicable term.
• Records: The general retention period is three years from submission of the final financial report, not simply three years from purchase or award close. Quarterly/annual reporting, real property/equipment, litigation/audits/claims, and transferred records can change the start date or extend retention. See 2 CFR 200.334.
• Personnel: 2 CFR 200.430 requires records that accurately reflect work performed and are supported by internal controls. It does not universally require a particular timesheet, signature, monthly PAR, semiannual certification, or quarterly reconciliation.
• Subrecipient or contractor: Make a case-by-case determination from the substance of the relationship under 2 CFR 200.331. A pass-through entity must provide required award information, evaluate subrecipient risk, review reports, follow up on deficiencies, and issue management decisions for findings pertaining to its award under 2 CFR 200.332. Site visits and fixed monitoring frequencies are risk-based tools, not universal mandates.
• Cost sharing: Voluntary committed cost sharing is generally not expected; when included in the approved budget it becomes binding. Counted cost share must satisfy 2 CFR 200.306, and unrecovered indirect requires prior federal approval.

Practical Impact in GrantLink

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

Important Notes

• Award terms can be more restrictive than federal defaults
• State or pass-through requirements may add controls
• Your accountant and auditor should confirm final treatment
• Agency implementation and each award's terms determine whether a 2024 flexibility applies to an older award
• The 2024 Federal Register final guidance, its official Federal Register PDF, and current 2 CFR Part 200 are the controlling starting points; the 2026 proposal should not be treated as final