In April 2024, the federal Office of Management and Budget rewrote 2 CFR Part 200, the Uniform Guidance that governs how federal grant money flows to nonprofits, universities, tribal organizations, and state and local governments. The most visible change: the threshold for triggering a federal Single Audit rose from $750,000 to $1,000,000 in federal awards expended, effective for fiscal years beginning on or after October 1, 2024. For organizations spending between $750,000 and $999,999 in federal funds, the audit burden technically disappeared.
In Florida, the picture is more complicated. The Florida Single Audit Act under F.S. § 215.97 did not follow the federal change. Florida’s state-level threshold for triggering a state single audit remains at $750,000 in state financial assistance. This means a Florida nonprofit can comfortably sit below the new federal threshold and still be required to obtain a single audit under state law — particularly if grant dollars from a state agency or a state pass-through entity are involved.
Why the mismatch matters
Consider a Florida nonprofit that expended $900,000 of federal funding in its most recent fiscal year. Under the new Uniform Guidance, no federal single audit is required. But if any meaningful portion of that funding originated from or passed through a Florida state agency — and qualifies as “state financial assistance” for purposes of F.S. § 215.97 — the organization may still be required to obtain a state single audit. Boards that read only the federal headline have walked into the new fiscal year assuming relief, only to find the audit obligation has shifted rather than disappeared.
Layered on top of all of this is Florida Statute 496.407, the Solicitation of Contributions Act administered by FDACS. Florida charitable organizations soliciting contributions in the state must register with FDACS, and those with $1,000,000 or more in contributions must file an audit; those between $500,000 and $1,000,000 must file a review; those between $200,000 and $500,000 must file a compilation. None of those thresholds moved when the federal single audit threshold changed. They all continue to apply — independently — for any nonprofit soliciting in Florida.
“The federal headline read like a threshold increase. The Florida reality is that for many organizations, three different audit regimes now apply in parallel, and they do not move together.”
How this shows up in the 2026 audit cycle
Three calendar pressures are converging on Florida nonprofits this year. First, the new federal threshold applies based on the award’s issuance date — awards issued before October 1, 2024 still operate under the $750,000 trigger, meaning many organizations face a dual-compliance environment that will persist through at least 2026. Second, the de minimis indirect-cost rate rose from 10% to 15% under the same Uniform Guidance rewrite, which affects both budgets and audit fieldwork. Third, the Florida $750,000 state threshold and the FDACS thresholds remain firmly in place, with their own filing deadlines and their own penalties for late submission.
The result is that the question for a Florida nonprofit’s board this year is not just “do we need an audit?” but “which audit, under which regime, with which submission deadline, and to which regulator?” Organizations that have answered those questions early are arriving at fieldwork without surprises. Those that have not are increasingly finding out after year-end — which is the worst possible time.
