Late Single Audits: What a Missed Single Audit Deadline Signals

The short version

• The single audit deadline is the earlier of 30 calendar days after the auditee receives the auditor's reports or nine months after the end of the audit period (2 CFR 200.512(a)(1)). A due date on a Saturday, Sunday, or federal holiday moves to the next business day.
• The cognizant or oversight agency for audit may authorize an extension when the nine-month timeframe would place an undue burden on the auditee. OMB has also granted blanket extensions and waivers, including six-month extensions in 2020 and 2021.
• A late single audit costs the auditee low-risk auditee status for the next two audit periods, because 2 CFR 200.520(a) requires timely submission in each of the preceding two. Continued failure to get an audit done can lead to remedies under 2 CFR 200.505 and 200.339.
• On the FAC, the Acc Date column shows when the audit was accepted. Compare it with the fiscal year end plus nine months. Dates on records migrated from the old Census clearinghouse are known to be unreliable.
• In our interpretation, a late filing can point to a stretched finance function, a slow close, or an auditor change. It can also have an ordinary explanation. Treat it as a question, not a verdict.

The single audit deadline rule

A nonprofit that expends $1,000,000 or more in federal awards in a fiscal year must have a single or program-specific audit for that year (2 CFR 200.501); see our Single Audit threshold guide for when the $1,000,000 level applies. The auditee, not the auditor, is responsible for making sure that audit is performed and submitted on time (2 CFR 200.508(a)).

The rule itself sits in 2 CFR 200.512(a)(1): the audit, the data collection form (Form SF-SAC), and the reporting package must be submitted within 30 calendar days after the auditee receives the auditor's reports or nine months after the end of the audit period, whichever is earlier. Program-specific audits follow the same timing unless their audit guide sets a different period (2 CFR 200.507(c)(1)).

In practice a finished audit cannot sit on a desk. If the auditor's reports arrive in November for a June 30 year end, the package is due in December, not March.

Extensions and past OMB relief

Two kinds of relief matter when you judge whether a filing was really late.

Individual extensions: under the current text of 2 CFR 200.512(a)(1), the cognizant agency for audit, or the oversight agency for audit when there is no cognizant agency, may authorize an extension when the nine-month timeframe would place an undue burden on the auditee. These approvals are not shown in the FAC search results described below, so an outsider usually cannot see them.

Blanket relief from OMB: the FAC archives OMB announcements. Examples relevant to older filings:

M-20-17 was issued as administrative relief for recipients affected by the COVID-19 crisis. Both M-20-17 and M-21-20 said recipients should keep documentation of the reason for the delayed filing, and that those using the extension would still qualify as a low-risk auditee under 2 CFR 200.520(a). An audit filed in late 2021 for a 2020 year may therefore have been on time.

What happens when a single audit is late or missing

The consequences are mostly indirect, and they build over time.

1. Low-risk auditee status is lost. Under 2 CFR 200.520(a), an auditee qualifies as low-risk only if, for each of the preceding two audit periods, single audits were performed annually and the data collection form and reporting package were submitted to the FAC within the 200.512 timeframe. One late filing affects the next two audits.
2. The audit gets bigger. For a low-risk auditee, major programs need to cover at least 20 percent of total federal awards expended; otherwise at least 40 percent (2 CFR 200.518(f)). Losing the status means more programs tested, which in our interpretation tends to mean more preparation work for the finance team.
3. Agencies and pass-through entities notice. Federal agencies should consider an applicant's history of performance, including compliance with reporting requirements, and reports and findings from subpart F audits when assessing risk before an award (2 CFR 200.206(b)). Pass-through entities must verify that subrecipients are audited as required (2 CFR 200.332(g)) and should consider prior audit results when evaluating risk (2 CFR 200.332(c)). Awarding agencies must ensure reports are received on time (2 CFR 200.513(c)(1)), and the FAC follows up with known auditees that have not submitted (2 CFR 200.512(g)).
4. Sanctions are possible for continued failure. 2 CFR 200.505 provides that in cases of continued inability or unwillingness to have an audit conducted, federal agencies or pass-through entities must take appropriate action as provided in 2 CFR 200.339.

The 200.339 toolkit starts with specific conditions under 2 CFR 200.208, which can include reimbursement instead of advance payments, more detailed financial reports, additional monitoring, a requirement to obtain technical or management assistance, and additional prior approvals. Where specific conditions cannot remedy the noncompliance, an agency or pass-through entity may temporarily withhold payments, disallow costs, suspend or terminate the award, start suspension or debarment proceedings, or withhold further federal funds.

Note the wording: 200.505 speaks to continued inability or unwillingness. A single late filing is not, by itself, described in the rule as a sanctionable event. Do not suggest to a prospect that it is.

How to check single audit filing dates on the FAC

The FAC search at app.fac.gov is free and covers audit years back to 2016.

1. Search by UEI or EIN, or by a whole word from the name. Audits submitted before April 2022 use an EIN; later ones use a UEI.
2. Read the Acc Date column. The FAC defines it as the date the FAC accepted the audit, and records the date the auditee certifying official confirms submission as the acceptance date.
3. Note the fiscal year end. The fiscal year end month is a search filter, and the downloadable data includes fy_end_date. The summary page for each audit links the SF-SAC and the PDF report.
4. Add nine months to the fiscal year end, roll a weekend or holiday to the next business day, and compare with the acceptance date.
5. Check the relief table above for the audit year before calling anything late.

For bulk work, the FAC data dictionary lists these date fields in the general table: date_created (first date any component was received), ready_for_certification_date, auditor_certified_date, auditee_certified_date, submitted_date, and fac_accepted_date.

Two cautions. First, the 30-day leg runs from when the auditee received the auditor's reports, and that receipt date is not among those fields. From outside, the nine-month outer limit is the test you can apply with confidence; a gap between auditor_certified_date and submission is at most a hint. Second, the FAC documents that acceptance dates on records migrated from the Census clearinghouse used the wrong historical field and were shifted by a day, and says that in theory a late audit may appear on time. Its results guide also notes that dates for records from September 2023 and before are one day earlier than submission. Treat pre-October 2023 dates as approximate.

A missing audit is harder still. Absence from the FAC only matters if the organization actually expended $1,000,000 or more in federal awards that year, and award data alone may not tell you that. Pair the FAC with federal award data and the organization's own filings before drawing any conclusion.

What a late single audit may signal for a finance firm

Everything in this section is interpretation. The filing date is verified; the reason for it is not.

The pattern matters more than the point. One filing a few weeks past the outer date says little. Two or three late years, combined with findings on reporting or close, and a summary of auditor's results stating the auditee did not qualify as low-risk (2 CFR 200.515(d)(1)(ix)), form a more coherent picture of a finance function that may welcome support.

How to approach a prospect respectfully

Label what you know before you reach out:

• VerifiedWhat the record states. "The fiscal year 2024 audit was accepted by the FAC about two months after the nine-month date."
• InferredA reasonable reading. "Year end close and audit preparation may be stretched across a small team."
• UnknownWhether an extension was approved, what caused the delay, and whether they want help.

Some practical rules:

• Never call the filing late in an opening message. You may not know about an extension or waiver.
• Lead with timing, not failure. "Audit season for a June year end lands on top of grant reporting. How has that been for your team?" is fair. "You missed your single audit deadline" is not.
• Do not mention sanctions, suspension, or debarment. 200.505 is about continued failure, and raising it reads as a threat.
• Check the most recent filing first. If the latest audit was on time, the problem may already be solved.
• Talk to the right person: the finance lead, controller, or executive director named in the SF-SAC certification or contact fields, not the board.

How AwardNote uses this

Sources

All retrieved October 29, 2026.

• 2 CFR 200.206, Federal agency review of risk posed by applicants (eCFR): ecfr.gov
• 2 CFR 200.208, Specific conditions (eCFR): ecfr.gov
• 2 CFR 200.332, Requirements for pass-through entities (eCFR): ecfr.gov
• 2 CFR 200.339, Remedies for noncompliance (eCFR): ecfr.gov
• 2 CFR 200.501, Audit requirements (eCFR): ecfr.gov
• 2 CFR 200.505, Remedies for audit noncompliance (eCFR): ecfr.gov
• 2 CFR 200.507, Program-specific audits (eCFR): ecfr.gov
• 2 CFR 200.508, Auditee responsibilities (eCFR): ecfr.gov
• 2 CFR 200.512, Report submission (eCFR): ecfr.gov
• 2 CFR 200.513, Responsibilities (eCFR): ecfr.gov
• 2 CFR 200.515, Audit reporting (eCFR): ecfr.gov
• 2 CFR 200.518, Major program determination (eCFR): ecfr.gov
• 2 CFR 200.520, Criteria for a low-risk auditee (eCFR): ecfr.gov
• OMB Memorandum M-20-17 (March 19, 2020): OMB memorandum (PDF)
• OMB Memorandum M-21-20 (March 19, 2021): OMB memorandum (PDF)
• Federal Audit Clearinghouse, Archived OMB announcements: fac.gov
• Federal Audit Clearinghouse, Search results guide: fac.gov
• Federal Audit Clearinghouse, Search filters: fac.gov
• Federal Audit Clearinghouse, Submitting an audit: fac.gov
• Federal Audit Clearinghouse, Current data dictionary: fac.gov
• Federal Audit Clearinghouse, Known data concern: acceptance dates: fac.gov
• Federal Audit Clearinghouse, Audit search: app.fac.gov
• HHS Office of Inspector General, Single Audits FAQs: oig.hhs.gov

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