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2 CFR Part 200 (Uniform Guidance): what it covers and who it binds

Source last checked: 1 August 2026 · 2 CFR Part 200, 2025 edition (govinfo PDF)

What does Part 200 actually establish?

Three things, and they are separable: uniform administrative requirements, cost principles, and audit requirements for federal awards. The regulation states this in one sentence at the top of Subpart B, and in the same passage it closes the door on agencies bolting on extras of their own.

The three blocks live in different subparts. Subparts B through D carry the administrative requirements, covering what agencies must do before an award is made and what they may impose on recipients and subrecipients across the award lifecycle. Subpart E holds the cost principles, which decide whether a cost is allowable — they do not address whether the government funds a particular project at all. Subpart F holds the single audit rules, issued under the Single Audit Act Amendments of 1996 (31 U.S.C. 7501–7507).

That split matters more than it looks. Almost every argument about Part 200 is really an argument about which subpart is in play, because the four subparts have four different reaches. Source: 2 CFR Part 200, pages 17–18 and 21 (govinfo PDF).

Who is bound — and who is not

The parties bound are federal agencies making awards, and "non-Federal entities" receiving them. The regulation defines that second term narrowly, and the definition is where most misreadings start.

Non-Federal entity (NFE) means a State, local government, Indian Tribe, Institution of Higher Education (IHE), or nonprofit organization that carries out a Federal award as a recipient or subrecipient.
2 CFR 200.1, page 14

Read the list again: a for-profit company is not on it. Neither is a foreign organisation, a foreign public entity, or another federal agency. Part 200 does not reach them by default.

It can reach them by choice. Agencies may apply Subparts A through E to federal agencies, for-profit organisations, foreign public entities or foreign organisations where their own regulations or the programme statute permit — with one carve-out: not where the agency determines that applying those subparts would be inconsistent with the international responsibilities of the United States or the laws of a foreign government.

Subpart F is different again, and stricter. The single audit rules apply only to non-Federal entities as defined in the Single Audit Act Amendments of 1996. An agency cannot extend Subpart F to a for-profit organisation the way it can extend the cost principles. So a company can find itself holding an award where the agency has imposed Part 200 cost rules by regulation, while the single audit requirement never attaches at all. Source: 2 CFR Part 200, pages 14 and 18 (govinfo PDF).

One rule cuts across all of this: the terms and conditions of federal awards, including Part 200 itself, flow down to subawards unless a section of the part or the award terms specifically indicate otherwise. Pass-through entities must comply with 200.331 through 200.333 regardless. Source: 2 CFR Part 200, page 18 (govinfo PDF).

Which subparts reach which kind of money

Not all of Part 200 applies to all federal financial assistance. Grants and cooperative agreements get the full treatment; loans, loan guarantees, interest subsidies and insurance get a much thinner slice. The table below is 200.101(b) compressed.

The exceptions in the right-hand column are the ones that get missed. Section 200.216, the prohibition on certain telecommunications and video surveillance equipment, applies to loans as well as grants. Sections 200.303 (internal controls) and 200.331 through 200.333 (subrecipient monitoring and management) apply to all types of federal financial assistance, so a loan programme that escapes most of Subpart D still carries the subrecipient-monitoring duties. Source: 2 CFR Part 200, pages 18–19 (govinfo PDF).

Where Part 200 stops and the FAR takes over

On a FAR contract, Part 200 applies only in fragments, and where the two conflict the FAR wins. This is the single most common way a page about the Uniform Guidance ends up pointing someone at the wrong regulation.

The split runs by contract type. On a cost-reimbursement FAR contract awarded to a non-Federal entity, only Subpart D at 200.331 through 200.333, plus Subparts E and F, are applicable. On a fixed-price FAR contract or subcontract, only Subpart A, Subpart B (minus 200.111, 200.112 and 200.113), Subpart D at 200.303 and 200.331 through 200.333, and Subpart E apply — and Subpart E drops out entirely for fixed-price contracts and subcontracts that are not negotiated.

Three precedence rules sit on top. Where the requirements of Part 200 conflict with the contract, the terms and conditions of the contract and the FAR prevail. Where the Cost Accounting Standards apply, they too take precedence over Part 200. And costs identified as unallowable under 41 U.S.C. 4304(a) and stated in the FAR (48 CFR part 31, subpart 31.2, and 48 CFR 31.603) are always unallowable, whatever Part 200 says. Source: 2 CFR Part 200, page 19 (govinfo PDF).

More broadly: with the exception of Subpart F, which the Single Audit Act requires, federal statutes and regulations govern wherever they conflict with Part 200. For agreements with Indian Tribes that includes the Indian Self-Determination and Education and Assistance Act (25 U.S.C. 5301–5423). Source: 2 CFR Part 200, page 19 (govinfo PDF).

Named programmes that Part 200 does not reach

A specific list of programmes is carved out by name, not by category, and there is no way to reason your way to it — you have to check the list.

Subparts C, D and E do not apply to: the block grant awards authorised by the Omnibus Budget Reconciliation Act of 1981 including Community Services (except that Subpart E reaches subrecipients of Community Services Block Grant funds under 42 U.S.C. 9916(a)(1)(B)); awards to local education agencies under portions of the Impact Aid programme (20 U.S.C. 7702–7703b); payments under the Department of Veterans Affairs' State Home Per Diem Program (38 U.S.C. 1741); and awards authorised under the Child Care and Development Block Grant Act of 1990, as amended. Sections 200.203, 200.216 and 200.331 through 200.333 still apply throughout.

A second, longer carve-out removes Subpart C only, and it covers entitlement awards under Social Security Act programmes including Temporary Assistance for Needy Families, Child Support Enforcement, Title IV–E foster care, Medicaid (but not the State Medicaid Fraud Control programme under 42 U.S.C. 1396b(a)(6)(B)) and the Children's Health Insurance Program; National School Lunch Act and Child Nutrition Act entitlement awards; state administrative expenses under the Food and Nutrition Act of 2008; and non-discretionary awards under WIC, the Emergency Food Assistance Programs and the Commodity Supplemental Food Program. Again, 200.203 and 200.216 survive the carve-out. Source: 2 CFR Part 200, pages 19–20 (govinfo PDF).

Separately, exceptions can be granted rather than legislated. OMB may allow class exceptions for classes of awards, recipients or subrecipients where not prohibited by statute. Agencies may adjust requirements for a class where a federal statute or regulation requires it — without OMB approval, and never for Subpart F. Agencies may also allow case-by-case exceptions for individual awards, except where prohibited by law; only the cognizant agency for indirect costs may authorise exceptions touching cost allocation plans or indirect cost rate proposals. Source: 2 CFR Part 200, page 21 (govinfo PDF).

A worked example: subrecipient or contractor?

If you are a company taking federal money through a university or a state agency rather than directly, this is the question that decides how much of Part 200 lands on you — and the label on the paperwork does not decide it.

Take a software firm engaged by a university that holds a federal research award. Two versions of the same engagement:

Version one. The firm sells the university 200 licences of a product it sells to hundreds of other customers, priced off its standard list, won against two competing bids. It has no say in who benefits from the research, its performance is measured against the licence agreement rather than against the programme's objectives, and the software is ancillary to the research. Those are the characteristics the regulation associates with a procurement relationship: the firm is a contractor.

Version two. The same firm is engaged to run the participant-recruitment arm of the study. It determines which applicants are eligible, makes programmatic decisions about how recruitment is executed, has its performance measured against whether the programme's objectives were met, and is responsible for adherence to the federal programme requirements in the award. Those are subrecipient characteristics: the engagement is a subaward, and Part 200 flows down to it.

The regulation lists these characteristics on both sides and then refuses to make them mechanical. All of the characteristics may not be present in every case, characteristics from both categories may be present at the same time, and no single factor or combination of factors is necessarily determinative. The pass-through entity must use judgment, and — the operative sentence — the substance of the relationship is more important than the form of the agreement. An agreement the pass-through entity considers a contract can still be a subaward.

Two further points people miss. The federal agency has no direct legal relationship with subrecipients or contractors of any tier; it is responsible for monitoring the pass-through entity's oversight of first-tier subrecipients instead. And one entity may concurrently receive federal awards as a recipient, a subrecipient and a contractor. Source: 2 CFR Part 200, pages 55–56 (govinfo PDF).

Two thresholds worth memorising

Most of Part 200 is qualitative, but two figures decide real outcomes and both are stated in the text.

The single audit threshold is $1,000,000. A non-Federal entity that expends $1,000,000 or more during its fiscal year in federal awards must have a single or program-specific audit conducted for that year. The trigger is what you expend in the year, not what you were awarded. Source: 2 CFR 200.501(a), page 103 (govinfo PDF).

The de minimis indirect cost rate is up to 15 percent of modified total direct costs. Recipients and subrecipients without a current federal negotiated indirect cost rate, provisional rates included, may elect it and may set their own figure anywhere up to that ceiling. Agencies and pass-through entities may not require a rate lower than the negotiated rate or the elected rate unless a federal statute or regulation requires it. It needs no documentation to justify its use, may be used indefinitely, and is not compulsory — but it must not be applied to cost-reimbursement contracts issued directly by the federal government under the FAR, and costs must be charged consistently as either direct or indirect, never double charged or inconsistently charged as both. Source: 2 CFR 200.414(f), page 70 (govinfo PDF).

What this page does not cover

Deliberately, so you know where to stop relying on it:

• Agency-specific implementations. Agencies making awards to non-Federal entities must implement the language in Subparts C through F in codified regulations unless different provisions are required by statute or approved by OMB. Your actual obligations are the agency's codified version plus your award terms, not this page (2 CFR Part 200, page 22).
• The cost principles item by item. Subpart E runs to dozens of individual cost categories — compensation, conferences, depreciation, lobbying, insurance, training — each with its own conditions. None of them are worked through here.
• Audit mechanics. Major programme determination, low-risk auditee criteria, report submission and audit findings all sit in Subpart F and are not covered above beyond the $1,000,000 trigger.
• The appendices. Indirect cost proposals for states, local governments, Indian Tribes, institutions of higher education, nonprofits and hospitals are governed by the appendices to Part 200, which have their own rules.
• Non-US regimes. Nothing here applies to EU or UK funding. Different regulations, different definitions, no read-across.

Frequently asked questions

Does 2 CFR 200 apply to for-profit companies?

Not by default. The definition of non-Federal entity covers states, local governments, Indian Tribes, institutions of higher education and nonprofit organisations only. A federal agency may apply Subparts A through E to for-profit organisations where its own regulations or the programme statute permit, so check the award terms and the agency's regulations rather than assuming either way. Subpart F, the single audit requirement, applies only to non-Federal entities and cannot be extended to you this way.

What is the single audit threshold under the Uniform Guidance?

$1,000,000. A non-Federal entity that expends $1,000,000 or more in federal awards during its fiscal year must have a single or program-specific audit for that year. The test is expenditure during the year, not the size of the award.

What is the de minimis indirect cost rate?

Up to 15 percent of modified total direct costs, available to recipients and subrecipients that have no current federal negotiated indirect cost rate. You may elect any rate up to that ceiling, it requires no documentation to justify its use, and it may be used indefinitely. It cannot be applied to cost-reimbursement contracts issued directly by the federal government under the FAR.

Is a subaward the same as a contract?

No, and the title on the paperwork does not settle it. A subaward passes on part of the federal award and creates a federal financial assistance relationship; a contract obtains goods or services and creates a procurement relationship. The pass-through entity decides case by case, and the substance of the relationship is more important than the form of the agreement.

Does 2 CFR 200 apply to federal contracts under the FAR?

Only in parts, and the FAR wins where they conflict. A cost-reimbursement FAR contract awarded to a non-Federal entity picks up Subpart D at 200.331 through 200.333 plus Subparts E and F. A fixed-price contract picks up Subpart A, Subpart B (minus 200.111, 200.112 and 200.113), Subpart D at 200.303 and 200.331 through 200.333, and Subpart E — and Subpart E falls away for fixed-price contracts and subcontracts that are not negotiated.

Do the Uniform Guidance rules apply to loans and loan guarantees?

Partly. Subparts A and B apply, except that 200.111, 200.112 and 200.113 do not. Subparts C and D do not apply, other than 200.203, 200.216, 200.303 and 200.331 through 200.333. Subpart E does not apply at all. Subpart F does apply to loans, loan guarantees, interest subsidies and insurance awarded to a non-Federal entity.

Can an agency add its own requirements on top of Part 200?

Only through defined routes. Federal agencies must not impose additional requirements except as allowed in 200.102 or 200.211, or unless specifically required by federal statute, regulation or Executive order. Legally binding requirements can only reach recipients and subrecipients through notice and public comment procedures under an approved agency process, or by being incorporated into the award's terms and conditions.

Which edition this page reads

The 2025 edition of 2 CFR Chapter II as published by the US Government Publishing Office, carrying the amendments at 89 FR 30136 (22 April 2024) and 89 FR 79732 (1 October 2024). Section numbers, page numbers and quotations above refer to that PDF. Part 200 is amended periodically; before you rely on any section here, open the current text and confirm it.

Source: 2 CFR Part 200 — Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, 2025 edition, US Government Publishing Office, a public domain document. Source last checked 1 August 2026. Every claim on this page is drawn from that text and cited to its page. Part 200 is amended periodically and agencies implement it in their own codified regulations; confirm against the current official text and your award terms before you rely on this. For the text of the twelve contract clauses themselves, see our guide to the clauses Appendix II requires — this page explains the rules, that one carries the clause text.