The 2025 Compliance Supplement Delay: What Auditors and Auditees Need to Know

If you’re a nonprofit, state or local government entity or educational institution subject to the Single Audit, you’ve likely heard that the Office of Management and Budget (OMB) has not yet released the final 2025 Compliance Supplement. Typically issued in late spring, the Compliance Supplement provides essential guidance for conducting audits of federal programs. Until it’s issued, Single Audits for June 30, 2025, year-ends (and others) cannot be finalized. The delay has left many wondering how to proceed. 

Why This Delay Matters

The Compliance Supplement is the playbook auditors use to test federal program compliance. Draft text may be available for planning, but it cannot be used to finalize your Single Audit. That matters for entities relying on timely audit reports for grantor deadlines, board reporting, and follow-on funding.

Current GAQC Guidance: Do Not Issue Single Audits Yet

The AICPA’s Governmental Audit Quality Center (GAQC) has issued a clear directive in GAQC Alert No. 488 stating:

“Auditors should not issue a June 30, 2025, year-end single audit until the final 2025 Compliance Supplement is released. The Supplement contains critical information that must be used in performing current-year single audits. While prior Supplements may help with planning, auditors will need to compare procedures to the final 2025 Supplement once issued.”

What To Do Now

• Communicate proactively with federal, state, and local funders about the possibility of a delayed Single Audit submission.
• Separate your financial statement audit from the Single Audit if filing the financials on time is critical. Note: Separate timing can increase total effort/cost.
• Prepare for dual submissions, especially for entities like HUD multifamily projects, which may require an Owner-certified submission followed by an audited one once the Supplement is released. 

Looking Ahead

The OMB has indicated that significant changes are not anticipated, but until the final Supplement is published, issuing Single Audit reports risks noncompliance and potential repercussions from federal agencies. We’ll continue monitoring GAQC and OMB updates and coordinate with our clients on timing and next steps.

Need Help Preparing?

For 40+ years, RGCO has served nonprofits and government agencies. We support 150+ not-for-profits each year—civic and social services, health and welfare, education, arts/culture/faith, trade associations, and private foundations—and provide trusted audits and consulting for governmental entities. Our team is experienced in Government Auditing Standards (Yellow Book), Uniform Guidance, Chapters 10.550 and 10.650 Rules of the Florida Auditor General, the Florida Single Audit Act, and other applicable standards. We can help you be ready the moment OMB issues the final 2025 Compliance Supplement.