Navigating the 2025 Compliance Supplement Delay: What Nonprofits and Government Entities Need to Know

ARTICLE | September 10, 2025

Is your organization experiencing anxiety about the delayed release of the 2025 Compliance Supplement? You’re not alone. The Office of Management and Budget (OMB) has pushed this critical document well past its typical release timeline, creating uncertainty across the nonprofit, governmental, and higher education sectors. Organizations with fiscal years ending on or after June 30, 2025, are now facing potential audit delays and compliance challenges that demand immediate attention and strategic planning.

Understanding the Current Situation

The 2025 Compliance Supplement delay represents more than a simple administrative setback. This comprehensive document provides auditors with essential guidance for conducting Single Audits, including specific audit objectives, suggested procedures, and compliance requirements for federal programs. Without it, auditors cannot officially complete or issue Single Audit reports for organizations with fiscal years ending June 30, 2025, or later.

The delay is particularly concerning given OMB’s improved track record in recent years. The supplement had been released before June 30 for three consecutive years, responding to industry requests for timely guidance. However, the 2025 version remains unreleased, with only vague promises of publication “in June” or later.

The National Association of State Auditors, Comptrollers and Treasurers (NASACT) has formally expressed concern to OMB, warning that continued delays will result in late Single Audits. In one documented case, three higher education oversight engagements required for reaccreditation are due to an accreditation association in early September, but the auditor cannot release the audit reports without the final supplement.

The Ripple Effect on Your Organization

This delay creates several immediate challenges for affected organizations. First, audit planning becomes significantly more complex when auditors must rely on draft guidance rather than official requirements. The AICPA Governmental Audit Quality Center has confirmed that while a final draft exists and can be used for planning purposes, it lacks official OMB clearance and cannot support final audit issuance.

Second, the uncertainty affects compliance timelines. Organizations must still meet their audit submission deadlines under the Uniform Guidance, but without completed audits, they face potential consequences including reaccreditation risks for higher education institutions and compliance violations for federal grant recipients.

The 2025 supplement is expected to include updated guidance reflecting the 2024 Title 2 revisions. It is expected that there will be guidance related to awards following the prior version of the Uniform Guidance, and separate guidance for awards following the 2024 revisions. This complexity likely contributes to the delay but also underscores the importance of having experienced audit professionals navigate these changes.

Proactive Steps During the Delay

While organizations cannot control OMB’s timeline, they can take meaningful action to minimize disruption. The most critical step is maintaining close communication with your audit team to understand how they plan to handle the delay and what preliminary work can be completed using the draft guidance.

Organizations should also review their internal compliance monitoring systems to ensure they’re documenting federal award activities thoroughly. When the supplement is finally released, having comprehensive documentation will expedite the audit process and demonstrate your commitment to accountability.

Additionally, this delay provides an opportunity to strengthen your organization’s understanding of federal compliance requirements. Rather than waiting passively, use this time to review current compliance procedures and identify areas for improvement.

How Insero Can Guide You Through This Challenge

At Insero Advisors, we understand that uncertainty creates stress, and we’re committed to helping our clients navigate this challenging situation with confidence. Our deep audit and compliance expertise, built over more than 50 years of serving growth-focused organizations, positions us to provide the guidance you need during this unprecedented delay.

Our team is actively monitoring the supplement’s development and maintaining communication with regulatory bodies to ensure we’re prepared to act quickly once the final version is released. We’re using the draft guidance for preliminary planning while preparing for any potential changes in the final version.

Most importantly, we’re helping our clients understand what they can control during this waiting period. Our proactive approach means we’re not just waiting for the supplement to be released but are actively preparing your organization for a smooth audit process once it becomes available.

The 2025 Compliance Supplement delay represents a significant challenge, but with proper preparation and experienced guidance, your organization can weather this uncertainty while maintaining its commitment to federal compliance and accountability.

Don’t let the 2025 Compliance Supplement delay catch your organization unprepared. Contact Insero Advisors today to discuss how we can help you navigate this challenging period and ensure your audit process remains on track. Our experienced team is ready to provide the guidance and support you need to maintain compliance and minimize disruption to your operations.