Nothing about your compliance obligations changed when the comment period closed. This article explains what is actually true right now, where to look first in your own documents, and how to use the waiting period without rewriting policies too early.
The public comment period for the proposed updates to the Uniform Guidance (2 CFR Part 200) has now closed, but the final rule has not yet been issued.
If your organization manages federal awards, you've probably had some version of this conversation over the last few weeks. Someone asks whether your policies need updating, while someone else points out that nothing is final yet. The conversation ends without a decision, and everyone moves on to the next thing.
That is an understandable place to land. It is also the moment where organizations quietly lose several months of useful preparation time. Here is what is actually true right now, and what you can do while you wait for the final guidance.
No. And it is worth saying that plainly to your team, because half-informed urgency creates more problems than the rule itself will.
A proposed rule is a proposal. It does not change a single requirement that applies to your awards today. The Uniform Guidance you have been following is still the Uniform Guidance you must currently follow. Your terms and conditions still govern, and your existing policies still apply.
The public comment period on the proposed rewrite of 2 CFR Part 200 closed on July 13th. That milestone matters a great deal to OMB's process, but it creates no obligation for you.
You may also have seen October 1st, 2026 mentioned as an effective date. Treat that as proposed rather than scheduled. The Federal Register entry for the proposed rule does not list an effective date at all, and proposed dates move.
Because nothing is due.
Almost everything else on your compliance calendar arrives with a deadline attached. Reports have dates. Audits have dates. Closeout has dates. This does not, so it slides, and then the final rule publishes and you are reading it for the first time under pressure.
There is a second reason, and it is the one that causes real damage. Some organizations overcorrect. They start rewriting procurement policies in August to match language that has not been finalized. If you do that, you can end up out of step with the rule that is actually in force while preparing for one that may never appear in that form.
You want to prepare without adopting anything early. That sounds like a fine distinction, but in practice, it’s the whole task.
Start with your own citations, because that’s where a renumbered rule will hurt you first.
Search your policies and procedures for anywhere you have written a specific section reference. If a policy says a purchase will be handled in accordance with a particular section of 2 CFR Part 200, and that section moves or is renumbered, you now have a document pointing at something that no longer exists.
You are not changing anything at this stage. You are building a list. Look for citations in:
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Procurement and purchasing policies
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Subrecipient monitoring procedures
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Allowable cost and cost allocation guidance
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Record retention schedules
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Any template or checklist your staff use day to day
When a final rule arrives, that list is the difference between an afternoon of updates and a month of hunting. (We put together a summary of the proposed changes in our Free Resources Library and key provision changes by section. 👉🏼
Access it here.)
Put your energy into the things that help you no matter what the final rule says.
Clean documentation helps you either way. A grant file that someone unfamiliar with the award could follow helps you either way. Written procedures that match what your staff actually do, rather than what someone wrote three years ago, help you either way.
It is also worth knowing which of your awards would feel a change first. Changes of this kind generally attach to new awards and new funding actions rather than reaching backward into awards already underway, so your exposure is uneven. If you have a continuation application coming up in the fall, that is your first point of contact. If you pass funding through to subrecipients, that is your second, because anything that changes for you eventually changes for them, and they will need lead time from you.
That is a short exercise. It tells you where to look the moment something publishes.
This is the step most organizations skip, and it costs them.
A final rule will be published at some point, and it will not arrive with an announcement addressed to your organization. Someone on your team needs to notice it.
Name that person. Give them somewhere specific to check rather than a general instruction to keep an eye out. Then decide in advance what happens when they see it: who reviews the changes, who tells program staff, and how quickly you expect to work through your citation list.
If nobody owns it, everybody assumes somebody else is watching.
The close of a comment period is a milestone in someone else's process. Nothing about your obligations changed on July 13th, and nothing will change until a final rule takes effect.
The organizations that handle transitions like this well are rarely the ones that moved fastest. They are the ones that knew where their own documents were, knew which awards were exposed, and had someone paying attention.
That is all very manageable between now and whenever the final rule appears.
