Key Takeaways

• Do not issue June 30, 2025 single audits yet — the 2025 Compliance Supplement has not been released.
• Be prepared to file an Owner-certified submission by September 30, 2025 if the Supplement is still pending.
• Once the Supplement is issued, an audited submission will be required (meaning two submissions may be needed).
• No significant changes are expected in testing for Sections 202, 811, or the Section 8 Cluster.
• Reassess filing decisions around September 20, depending on the Supplement’s release status.
• The final 2025 Compliance Supplement will be announced by OMB and posted publicly when released; AHACPA will notify subscribers.

As you may know, the Office of Management and Budget (OMB) has not yet released the final 2025 Compliance Supplement. AHACPA has received many calls and emails relating to this delay, which affects nonprofit multifamily projects that are subject to single audit requirements. Guidance from the AICPA indicates that such financial statements should not be filed at this time due to delays in the compliance production of the 2025 Compliance Supplement by the Office of Management and Budget. For those who may not belong to the GAQC, we have included the specific prohibition on issuance of the reports prior to the Supplements final issuance:

According to GAQC Alert #488, auditors should not issue a June 30, 2025, year-end single audit until the final 2025 Compliance Supplement is released. The AICPA explains that the Supplement contains critical information that must be used in performing current-year single audits. While prior Supplements may help with planning, auditors will need to compare procedures to the final 2025 Supplement once issued.

HUD’s Assessment Center (formerly the Real Estate Assessment Center (REAC)) has not announced a blanket extension. Because an Owner-certified submission option exists, they may not issue one. However, this could change as the September 30 deadline approaches.

AHACPA’s recommendation: Auditors should be prepared to file an Owner-certified submission by September 30, 2025. Once the 2025 Compliance Supplement is officially issued, an audited submission will be required. This means two submissions may ultimately be needed in FASSUB. Users of AHACPA’s submission services will be less affected, as their data will already be in our upload tool and will only require minor adjustments.

The draft 2025 Compliance Supplement did not indicate material changes to the three primary programs (Sections 202 and 811, and the Section 8 Cluster). This suggests there should be no major changes to audit testing once the final Supplement is released.

It is important to note that we are still nearly a month away from the September 30 deadline, and it is possible the Compliance Supplement will be issued before then. Auditors should plan to make a final decision about filing around September 20, based on the status of the Supplement at that time.