Update on the 2025 and 2024 Compliance Supplements

Article | October 28, 2025 | Atchley & Associates LLP

In August 2025, the Office of Management and Budget (OMB) released a draft version of the 2025 Compliance Supplement. This draft is intended solely for planning and preparation purposes; auditors are not permitted to issue final Single Audit reports based on the draft document.

The American Institute of CPAs (AICPA) has clarified that auditors are unable to issue Single Audit reports for entities with a fiscal year ending June 30, 2025, or later, until the official final version of the 2025 Compliance Supplement is released. This issuance halt means that audits for these periods must be postponed until further guidance is provided.

Organizations subject to a Single Audit should engage in proactive communication with both auditors and federal funders. This will help manage expectations regarding the timing and submission of audit reports, especially in light of current delays.

2024 Compliance Supplement and Key Changes

Since the 2025 supplement has not yet been finalized, the 2024 Compliance Supplement remains the authoritative guidance for audits of fiscal years beginning before July 1, 2024. Auditors preparing for 2025 audits should refer to the 2024 document for the most current finalized information.

The 2024 Compliance Supplement, which was released in May 2024, introduced several significant changes compared to the previous year:

Increased Audit Threshold: For fiscal years starting on or after October 1, 2024, the threshold for Single Audits increased from $750,000 to $1 million in federal awards expended.

Changes to Higher-Risk Programs: The list of programs designated as "higher risk" was updated, impacting audit planning and procedures. For the first time, the draft 2025 version removes COVID era funding from the Higher-Risk Programs (ALN 21.023 and 21.027). This can cause new programs to be looked at as major programs and audited in 2025.

We will keep monitoring any updates regarding compliance supplements and related federal guidance. Staying informed about changes will ensure that audit processes remain compliant and minimize disruptions caused by evolving requirements.

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