The 2025 Compliance Supplement Waiting Game: What Non-Profits Need to Know
Published on by Kelsey Oliver in Not-for-Profit
If you are a non-profit leader experiencing uncertainty while awaiting the release of the Office of Management and Budget’s (OMB) 2025 Compliance Supplement, you are not alone. Many organizations are in a similar position, preparing for upcoming single audits without clear federal guidance.
The OMB customarily issues its annual Compliance Supplement before June 30, providing organizations with essential direction for conducting federal program audits. However, in 2025, the release has been delayed, leaving many entities waiting for critical updates necessary to ensure compliance and effective audit preparation.
Why this delay matters
Think of the Compliance Supplement as your non-profit’s GPS for navigating single audits. Without it, auditors can’t issue your single audit report. The delay is driven by significant revisions to the Uniform Guidance and has been further impacted by the federal government shutdown. The aforementioned revisions are discussed in our earlier blog post on updates to the Uniform Grants Guidance. While the OMB did release a draft version of the 2025 Compliance Supplement in August, the American Institute of Certified Public Accountants (AICPA) has made it clear: no final supplement means no final single audit report.
The supplement tells auditors which compliance requirements to test for each federal program, helping both you and your auditors focus efforts where federal agencies say it matters most. Without this guidance, everyone is working with educated guesses rather than concrete requirements. At present, the OMB has not yet announced an extension of the nine-month deadline for submitting single audits to the Federal Audit Clearing House.
What non-profits should be doing right now
While you can’t control the OMB’s timeline, you can control your response. Here’s what we’d advise:
- Stay connected with your audit team: Have regular conversations about timing and strategy.
- Communicate proactively: Keep your Board, Audit or Finance Committees, and funders in the loop. Nobody likes surprises, especially when it comes to audit timelines. Transparency now prevents frustration later.
- Use the draft Compliance Supplement as a planning tool: While it’s not final, it can help with preliminary planning. Just remember to compare it carefully to the final version when it’s released.
The silver lining
While delays aren’t ideal, they do underscore something important: the value of strong year-round compliance practices. Organizations with robust internal controls and documentation processes weather these uncertainties much better than those who scramble at year-end.
This delay also highlights why having experienced auditors who understand non-profit compliance is crucial. They can help you navigate the uncertainty and ensure you’re prepared to move quickly once guidance is finalized.
Looking forward
Remember, this delay isn’t a reflection of your organization’s compliance efforts. It’s a systemic issue affecting everyone subject to single audit requirements. The key is staying prepared, maintaining open communication, and working with advisors who can help you navigate the uncertainty.
Need guidance on how these supplement delays might impact your non-profit? As always, we’re here to help navigate these uncertain waters. Contact us today to schedule a free consultation with one of our non-profit pros who can help you develop a strategy for managing audit timing and compliance requirements during this waiting period.
