As of the release date of this product, the 2025 Compliance Supplement has not been published. However, in August 2025, the OMB released a
final draft version
of the 2025 Compliance Supplement to the AICPA for release to practitioners for use in audit planning pending the issuance of the final approved Compliance Supplement. This product was updated based on the 2025 Compliance Supplement (final draft version), which includes the requirements and guidance for audits conducted under both the Uniform Guidance, October 2023 revision, and the Uniform Guidance, April 2024 revision. Auditors should be alert for
the release of the 2025 Compliance Supplement. The AICPA stated in GAQC Alert 488 that it would not be appropriate for auditors to issue single audit reports for auditees with fiscal years ending June 30, 2025, and later before the release of the final 2025 Compliance Supplement. The 2025 Compliance Supplement (final draft version) will assist auditors by allowing them to begin planning their engagements.
This product should be used for audits subject to OMB’s
Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards
(Uniform Guidance), October 2023 revision or OMB’s
Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards
(Uniform Guidance), April 2024 revision. There will be two versions of the Compliance Supplement included in the product, with the title including the corresponding threshold, i.e. 2025 Compliance Supplement (Final Draft Version) ($750,000) or 2025 Compliance Supplement (Final Draft Version) ($1,000,000).
In April 2024, the OMB issued revisions to the Uniform Guidance. The government-wide effective date of the revisions was October 1, 2024; however, federal agencies could have elected to implement the revisions as early as June 21, 2024 or as late as October 1, 2025. Appendix VII of the 2025 Compliance Supplement (final draft version) states that both the increases in the single audit threshold and the major program determination threshold (i.e., the Type A program threshold) from $750,000 to $1,000,000 are effective for auditee fiscal years beginning on or after October 1, 2024 (generally for fiscal years ending September 30, 2025, and later). It states that the threshold changes will be effective regardless of whether the awarding agencies take action to amend existing awards. Auditors should note that this effective date does not coincide with the effective date of the annual Compliance Supplement update (i.e., single audits for entities with fiscal years ending June 30, 2025, through September 29, 2025, are subject to the 2025 Compliance Supplement, but not the increased single audit or Type A program thresholds). All other Subpart F—Audit Requirements revisions are effective on October 1, 2024. Auditors and auditees should be alert for further guidance from the OMB and federal agencies.