Uniform Guidance changes 2026: what OMB proposed and when it could apply
By Wesley Stevens, Founder of Quillify. Office of Management and Budget. November 2, 2026. Read the source.
What changes did OMB propose to the Uniform Guidance in 2026?
On May 29, 2026, the Office of Management and Budget (OMB) proposed a rewrite of the Uniform Guidance, the rules every federal grant follows, in Federal Register document 2026-10817. Comments closed July 13, 2026. Section 157 of the continuing resolution bars finalizing it through December 11, 2026. The 2024 Uniform Guidance still governs federal awards.
Where things stand
OMB published the proposal, titled “Regulation for Federal Financial Assistance,” on May 29, 2026, at 91 FR 32198. Comments closed July 13, 2026. OMB proposed a final rule effective by October 1, 2026, so that a single set of requirements would apply to awards made in fiscal year 2027.
No final rule had appeared in the Federal Register by that date. Section 157 of the continuing resolution, H.R. 6500, now says the rule, or a substantially similar one, “shall not be issued or finalized” through December 11, 2026. What happens after December 11 depends on the next spending law.
The changes, section by section
Termination, 2 CFR 200.340. Today’s rule lets an agency end an award under its terms and conditions “if an award no longer effectuates the program goals or agency priorities,” to the extent the law allows. The proposal would let an agency end an award when it decides termination is in its interest. That includes an award that no longer serves “program goals, Federal agency priorities, or the national interest” as they stand at the time. Every discretionary award would carry this clause. Programs where a statute entitles the recipient to the funds, such as block grants, formula grants, and disaster recovery grants, would be exempt.
Stop-work orders, 2 CFR 200.340(d). A new paragraph would let an agency or pass-through entity issue a written order to pause work. The agency would have to account for the effect on the recipient’s budget and schedule.
Termination notices, 2 CFR 200.341. Today a notice should give the reasons, the effective date, and the portion terminated. A discretionary termination notice would also need a brief summary of why the agency decided to end the award. It would tell the recipient to stop work and make no new financial obligations. It would invite a short written statement on termination costs.
Objections and appeals, 2 CFR 200.342. OMB proposes only minor changes here. An agency would still owe a recipient a chance to object when it acts for noncompliance. A discretionary termination would carry no administrative hearing unless another law requires one.
Costs after termination, 2 CFR 200.343. The proposal adds that a recipient must make all reasonable efforts to cancel or reduce obligations it incurred before the effective date, and document those efforts on request. A new paragraph would let agencies allow further costs after a discretionary termination.
Award terms, 2 CFR 200.211. Every award would include the termination provisions of 200.340 or incorporate them by reference.
Review before award, 2 CFR 200.205. Senior appointees would review proposals selected for funding before awards are made, to confirm each one fits applicable law, federal agency priorities, and the national interest. Peer review would stay advisory. Posting a funding notice would not oblige an agency to make awards.
Applicant risk, 2 CFR 200.206. Agencies could weigh more factors, including an applicant’s capacity to manage high-dollar awards and a history of questionable practices drawn from public, verifiable information.
Funding notices, 2 CFR 200.204. Agencies would announce every discretionary funding opportunity, including ones not openly competed. Applications would go through Grants.gov unless an exception applies. The 500-word limit on a notice’s executive summary would become a requirement. A notice open for fewer than thirty days would have to state the exigent circumstances behind it. Agencies would be encouraged to use short statements of interest when they expect many applications.
Program design, 2 CFR 200.202. Agencies would be encouraged to make multiyear awards with budget periods longer than one year in place of annual re-competition. Program goals would have to align with administration policies and priorities.
Fixed amount awards, 2 CFR 200.201. New fixed amount awards and subawards would end unless a statute authorizes them. OMB states the change is not intended to affect fixed amount awards issued before the rule takes effect.
Payments, 2 CFR 200.305. Agencies would check recipients against Treasury’s Do Not Pay system before each disbursement. Once agency systems are ready, payment requests from recipients other than states would describe the purpose of each payment and the award work it supports.
National policy requirements, 2 CFR 200.300. To the maximum extent the law allows, awards could not fund or promote diversity, equity, and inclusion practices that violate federal anti-discrimination law. The same paragraph would cover “gender ideology” as Executive Order 14168 defines it and the gender transition of anyone under nineteen.
Indirect costs, 2 CFR 200.414. The proposal leaves the indirect cost rate negotiation system as it is. OMB said it may request information on the topic in the future.
What stays the same
Until a new rule takes effect, the 2024 Uniform Guidance governs. These are the provisions a grantee works with most, as the current text of 2 CFR part 200 states them.
Single audit at $1,000,000. An organization that spends $1,000,000 or more in federal awards in its fiscal year needs a single or program-specific audit (2 CFR 200.501). Below that amount it is exempt from federal audit requirements for the year, though its records stay open for review.
De minimis indirect rate of up to 15 percent. An organization without a negotiated rate may charge up to 15 percent of modified total direct costs. The rate needs no documentation to justify it (2 CFR 200.414(f)).
Equipment at $10,000. Equipment is property with a useful life of more than one year and a per-unit cost at or above the lesser of your capitalization level or $10,000 (2 CFR 200.1).
Closeout in 120 days. Final reports and the liquidation of obligations are due within 120 calendar days after the period of performance ends (2 CFR 200.344).
Termination terms in writing. The agency must “clearly and unambiguously specify all termination provisions” in the award’s terms and conditions (2 CFR 200.340(b)). Costs properly incurred before a termination’s effective date stay allowable when they would have been allowable had the award ended normally (2 CFR 200.343).
Funding notices open for sixty days. Agencies should keep opportunities open for at least sixty calendar days. None should run fewer than thirty days unless exigent circumstances justify it (2 CFR 200.204(b)).
Read the current rules on eCFR, 2 CFR part 200.
What to do now
Read your award terms. Find the termination clause and the grounds it lists. Today’s rule requires those grounds in writing, so the award document tells you which ones apply to you.
Keep records that would support an objection. Progress reports, prior approvals, and correspondence with your program officer show the work matches the award. They also support any claim for costs incurred before an effective date.
Keep applying. Awards made today follow the 2024 rules. Quillify reads new federal funding announcements as they post and matches each one to what your organization does.
What a continuing resolution means for your award. Federal grants for 2027: what’s settled and what’s still open.
What you can do today
More policy news: NIH webinar notices, October 26 to 28, 2026. The 2026 proposal to trim HHS block grant regulations. The 2026 final rule trimming child support program regulations. USDA SPUR guaranteed loans for FY 2027: who qualifies and how to apply. SBA surety bond guarantee fees: what changes on November 30, 2026.
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