Single Audit Threshold Guide: Do You Need a Single Audit?
You need a Single Audit if your organization expends $1,000,000 or more in federal awards in a fiscal year, per 2 CFR 200.501. The threshold was raised from $750,000 and applies to fiscal years beginning on or after October 1, 2024. Count expenditures — not awards received — including pass-through funds from states and cities, the value of federal loans, and non-cash assistance. The completed audit must reach the Federal Audit Clearinghouse within 9 months of fiscal year end.
What Counts Toward the $1,000,000 Single Audit Threshold?
The threshold measures federal awards expended during your fiscal year — combined across every federal agency and every funding path.
Direct Federal Grants & Cooperative Agreements
Grants received directly from federal agencies — HHS, HUD, DOL, DOE, USDA, EPA, NEA, and others. Expenditures are measured when the activity occurs, not when cash is drawn down.
Source: 2 CFR 200.502 — Basis for determining Federal awards expended
Pass-Through Awards (Subrecipient Funds)
Federal funds passed through a state, county, city, or another nonprofit keep their federal character and count toward your threshold if you are a subrecipient. Vendor/contractor payments generally do not count — the subrecipient vs. contractor determination under 2 CFR 200.331 is decisive.
Federal Loans & Loan Guarantees
The value of new federal loans made during the year plus prior-year loan balances with continuing compliance requirements count as federal awards expended under 2 CFR 200.502 — a frequent surprise for organizations with federally guaranteed financing.
Non-Cash Assistance
Federally furnished commodities (such as USDA food programs), donated property, free rent tied to a federal program, and insurance in effect during the year all count at fair value. Organizations relying only on their cash ledger routinely undercount.
How Major Programs Are Determined — and When Your Audit Is Due
Two things every first-time Single Audit organization should understand before fieldwork begins.
Major Program Determination
2 CFR 200.518Under the risk-based approach in 2 CFR 200.518, the auditor identifies larger Type A programs, assesses their risk, then evaluates higher-risk Type B programs. Compliance testing must cover at least 20% of total federal expenditures — 40% if you are a high-risk auditee.
9-Month FAC Deadline
fac.govThe reporting package — financial statements, SEFA, auditor's reports, findings, corrective action plan, and Form SF-SAC — must be submitted to the Federal Audit Clearinghouse at fac.gov within 30 days of the auditor's report, or 9 months after year end, whichever is earlier.
Yellow Book vs Single Audit
A Yellow Book (GAGAS) audit is a financial statement audit under Government Auditing Standards. A Single Audit is a Yellow Book audit PLUS major program compliance testing against the OMB Compliance Supplement and a SEFA opinion. Every Single Audit is a Yellow Book audit — not vice versa.
What Happens If You Miss a Required Single Audit?
Federal agencies and pass-through entities have escalating remedies for late or missing Single Audits.
Payment Suspension & Withheld Drawdowns
Federal agencies and pass-through entities can withhold reimbursements and suspend drawdowns until a compliant audit is filed — an immediate cash flow crisis for grant-dependent organizations.
High-Risk Auditee Designation
A late filing costs you low-risk auditee status for the next two years, raising required major program coverage from 20% to 40% of federal expenditures — which directly increases future audit scope and cost.
Disallowed Costs & Added Award Conditions
Costs charged to federal awards can be questioned and disallowed, and agencies can impose specific conditions under 2 CFR 200.208 — more frequent reporting, reimbursement-only payment, or additional monitoring.
Loss of Future Funding Eligibility
Funders check the Federal Audit Clearinghouse before making awards. A missing or delinquent Single Audit can disqualify applications, block subaward closeouts, and in persistent cases lead to suspension or debarment.
Single Audit Threshold — Old vs Current Rules
Which threshold applies depends on when your fiscal year BEGINS (2 CFR 200.501, 2024 Uniform Guidance revisions)
| Feature | Fiscal Year Begins | Threshold | Example |
|---|---|---|---|
| Before October 1, 2024 | $750,000 | FY July 1, 2024–June 30, 2025 → $750K applies | |
| On or after October 1, 2024 | $1,000,000 | FY January 1, 2025–December 31, 2025 → $1M applies | |
| Below threshold | No Single Audit | Records must still be available for review (2 CFR 200.501(d)) | |
| One federal program only | Program-specific audit may be an option | Available when financial statement audit isn't otherwise required |
Related Audit & Compliance Services
Nonprofit Audit Services
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Government Contractor Audit
DCAA and federal award compliance audits for government contractors.
Audit & Attestation Services
Full audit, review, compilation, and AUP services from a licensed CPA firm.
Single Audit Threshold FAQs
Common questions from executive directors, CFOs, and grant managers about the $1,000,000 requirement.
Not Sure If You Cross the $1 Million Threshold?
Send us your grant list and we'll walk through the expenditure math with you — pass-through funds, loans, and non-cash assistance included — and tell you exactly whether a Single Audit is required and what it will take.
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