The Office of Management and Budget (OMB) announced a delay in releasing the 2025 OMB Compliance Supplement due to administrative backlogs. Traditionally issued in May, this annual publication provides essential guidance that auditors rely on when performing Single Audits for organizations receiving federal awards.
Understanding the Single Audit Landscape
Single Audits are a critical compliance requirement for organizations that expend $750,000 or more in federal awards during their fiscal year.[1] In fiscal year 2023 alone, over 40,000 Single Audits were submitted to the Federal Audit Clearinghouse, representing billions of dollars in federal funding across nonprofit organizations, educational institutions, and state and local governments.[2]
The Compliance Supplement serves as the auditor’s roadmap, providing program-specific audit guidance for the largest federal programs. Without this finalized document, auditors cannot complete the compliance testing required to issue an official Single Audit opinion—even when all fieldwork has been completed.
Key Considerations for YOUR Organization
If your organization receives federal funding and has a June 30, 2025 fiscal year-end, this delay could impact the timing of your audit deliverables:
The Single Audit cannot be finalized until the official 2025 Compliance Supplement is released by OMB.
This delay may affect the timely submission of audit reports to federal agencies or pass-through entities. Under the Uniform Guidance, Single Audits must typically be submitted within nine months of fiscal year-end—meaning March 31, 2026 for June 30, 2025 year-ends.[3]
However, your financial statement audit can still be completed and issued separately without interruption.
Why This Matters More Than You Think
Organizations facing audit delays may encounter several cascading challenges:
Grant reimbursement delays: Some federal agencies may hold payments pending receipt of compliant audit reports
Compliance concerns: Late audit submissions can trigger findings in subsequent years
Board and stakeholder relations: Delays require careful communication to maintain confidence
Future funding at risk: Patterns of late audit submissions may impact future grant applications
According to recent federal oversight data, approximately 15% of Single Audits are submitted after their deadline each year, with delays often cited as a contributing factor to findings in subsequent audit periods.[4]
How HBK Is Responding
Our firm has obtained the draft version of the 2025 Compliance Supplement through the AICPA Government Audit Quality Center (GAQC). While this draft cannot be used to issue final Single Audit reports, it enables our engagement teams to:
Begin preliminary planning for Single Audit engagements.
Identify key compliance areas and potential changes from prior years.
Prepare audit procedures and programs in advance of the official release.
Maintain momentum on your engagement to minimize delays once the final Supplement is published.
At this time, OMB has indicated that no significant revisions are anticipated between the draft and final versions of the Supplement.
What Makes This Situation Different
Unlike routine audit planning, this administrative delay is entirely outside your organization’s control. The challenge lies in maintaining audit progress while managing stakeholder expectations. Organizations that proactively address this situation demonstrate strong governance and accountability—qualities that strengthen relationships with funders and oversight bodies.
Next Steps
Financial Statement Audit: You may proceed with your financial statement audit as planned. We recommend discussing with your audit team and users of your financial statements the option to issue the financial statement audit separately from the Single Audit if reporting deadlines require it.
Single Audit: Planning and preliminary fieldwork may continue, but the final Single Audit report cannot be issued until the official 2025 Supplement is published.
Communication Strategy: We encourage proactive communication with federal agencies, pass-through entities, and major donors to inform them of the potential delay and to align expectations regarding report submission timelines. Consider these key messages:
Acknowledge the delay and its industry-wide impact
Confirm your organization’s commitment to compliance
Provide updated timeline expectations once the Supplement is released
Highlight steps being taken to minimize the ultimate delay
Our Commitment
HBK is closely monitoring updates from both the OMB and the AICPA GAQC and will promptly notify clients once the final 2025 Compliance Supplement is released. Our team remains committed to completing your audits efficiently, accurately, and in full compliance with all federal requirements.
You don’t have to navigate this complexity alone. With our proven track record as a Top 50 accounting firm specializing in governmental and nonprofit audits, we understand the unique challenges your industry faces. Our experts have guided hundreds of organizations through audit complexities, ensuring compliance while minimizing disruption to your operations.
For questions about how this delay may affect your organization—or for assistance with stakeholder communication—please contact your HBK engagement team or reach out to our A&A Specialist Group.
Footnotes:
[1] 2 CFR § 200.501, Audit Requirements, Office of Management and Budget Uniform Guidance (2024).
[2] Federal Audit Clearinghouse, U.S. Census Bureau, “Single Audit Database Statistics” (data as of September 2024), https://facweb.census.gov/
[3] 2 CFR § 200.512(a), Report Submission, Office of Management and Budget Uniform Guidance (2024).
[4] U.S. Government Accountability Office, “Single Audit: Opportunities Exist to Improve Oversight and Address Audit Quality Issues,” GAO-22-104450 (November 2022).
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