The 2026 Uniform Guidance Transition Checklist | The Grant Project
Free Transition Checklist

The Uniform Guidance is changing. Here's exactly what to do before it does.

The proposed 2026 revision to 2 CFR Part 200 could take effect as early as October 1, and it reaches far more than fixed amount awards. It restructures how grants are paid, monitored, reported, and terminated. This checklist turns the changes into the specific actions that keep your organization compliant, sequenced by where you sit in the funding chain.

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$1.25B+
secured in competitive funding
20+ yrs
federal grants management experience
4
funding-chain roles mapped to action
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This checklist is for you if

✓

You are not sure which sections of the new guidance actually apply to your organization

✓

You pass any federal dollars to subrecipients, affiliates, or subsidiaries

✓

You are bracing for slower reimbursements once payment justification and Do Not Pay screening apply

✓

You have an open audit finding that still needs a documented corrective action

✓

You could not tell someone, today, what happens to your program in the first 30 days if an award terminates

✓

You hold a fixed amount award or subaward, a structure the proposed rule eliminates

Built around your role

Four paths through the funding chain. You may be on more than one.

Section 1

Every Organization

The ten foundational actions every federally funded organization completes before October 1.

Applies to everyone
Section 2

Direct Recipients

You hold the award directly from a federal agency and run your own programs.

Complete Sections 1 & 2
Section 3

Pass-Through Entities & Primes

You subaward, regrant, or pass federal funds to other organizations.

Complete Sections 1, 2 & 3
Section 4

Subrecipients

You receive federal funds through a state agency, local government, or nonprofit prime.

Complete Sections 1 & 4
What actually changes

Nine areas of the framework move at once. Three reach you fastest.

Fixed amount awards are eliminated

Every award and subaward on that structure moves to cost monitoring and financial reporting, with no grandfathering.

Any org holding one
Payment requests need justification

Treasury Do Not Pay screening runs before funds move, which adds time between your draw request and your deposit.

Direct recipients & pass-throughs
Termination authority expands

Agencies may end awards for any lawful program or policy reason, at any point in the period of performance.

Every recipient & subrecipient
Section 1
Every Organization
Inventory every award
Flag fixed amount awards
Confirm SAM.gov status
Update COI policy
Section 2
Direct Recipients
Build cost accounting
Template payment justification
Model the cash flow gap
Write a continuity plan
What's inside

An 8-page roadmap, not another summary of the Federal Register.

  • ✓A quick-reference table that maps your role to the exact sections you need, in order
  • ✓Every action written as a task, not a regulation citation, so your team can just start working
  • ✓A "where to focus first" callout for teams who can only tackle three things this month
  • ✓A 90-day roadmap sequencing the work from inventory in July to go-live October 1
  • ✓Flow-down provisions to update in subaward agreements if you pass funds downstream
Who built this

The Grant Project

The Grant Project partners with local governments and nonprofits to build the readiness, compliance, and strategy behind successful federal funding. With more than 20 years of federal grants management experience and over $1.25 billion in competitive funding secured, TGP translates regulatory complexity into systems that working teams can actually run. This checklist is a piece of that work, made free for you.

Before you download

Questions we hear from grant teams right now

Is this official guidance, or TGP's interpretation of it?
This checklist is built directly from the 2026 revision to 2 CFR Part 200, published May 29, 2026 at 91 FR 32198, effective October 1, 2026. It translates the published requirements into sequenced actions. It is not legal advice, and organizations with open legal or compliance questions should still involve counsel.
My funding agency hasn't issued its adopting regulations yet. Why start now?
Agency-specific terms will land in 2 CFR Subtitle B as each agency adopts the framework. The foundational work, your award inventory, your fixed amount award flags, your SAM.gov status, your conflict of interest policy, does not wait on any single agency. Starting now means the agency-specific terms slot into a system you have already built.
We don't have a dedicated compliance officer. Can we still use this?
Yes. The checklist is written for small teams handling this alongside their regular workload. The 90-day roadmap on the last page sequences the work into pieces a grant manager or finance director can complete in July, August, and September without adding headcount.
Does this apply to us if we've never held a subaward?
Complete Section 1, which applies to every organization touching federal money, and Section 2 for direct recipients. Section 3 only applies the moment a single dollar of federal money leaves your organization and lands in another one to carry out part of the program. If that never happens, you can skip it.
What if the requirements shift again before October 1?
The checklist points you to where to watch, including SAM.gov and each funding agency's adopting regulations in 2 CFR Subtitle B, so your team can adjust the specifics without redoing the underlying systems.
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