On May 29, 2026, the Office of Management and Budget published a proposed rule in the Federal Register — “Regulation for Federal Financial Assistance” (document 2026-10817), docketed as OMB-2026-0034 — that would rewrite 2 CFR Part 200, the Uniform Guidance that has governed federal grants and cooperative agreements since 2013. The public comment period closed July 13, 2026. This piece covers what the proposal would actually change and where it stands now that comments are in — not a re-explanation of the Uniform Guidance as it currently stands, which CASRAI covers elsewhere (see our guides on federal grant reporting requirements and pre-award costs under 2 CFR 200.458).
What OMB Proposed, and When
The proposal is described by OMB and by the grantmaking agencies coordinating on it as the largest revision to the Uniform Guidance since it was first issued in 2013. Structurally, it would reclassify OMB’s government-wide requirements in 2 CFR Subtitle A from non-binding “guidance” into a formally binding OMB regulation — a change legal and higher-education-policy commentary has referred to informally as the “Uniform Grants Regulation.” That reclassification matters procedurally as much as substantively: guidance can be revised by OMB with relatively little process, while a binding regulation is subject to the full notice-and-comment cycle this proposal is itself going through.
Scope: Who This Would Affect
2 CFR Part 200 applies government-wide to essentially every recipient of federal financial assistance, and the proposed rule follows that same scope. Reporting on the proposal from higher-education and county-government associations (the National Association of Counties, among others) describes it as reaching every major federal grantmaking agency — NIH, NSF, DOE, CDC, and the rest of the federal grant-making apparatus — and every category of recipient: universities and research institutions, state and local governments, nonprofits, scientific and professional societies, and, as flow-down terms, subrecipients and individual award recipients under those primary awards.
The Substantive Changes Under Discussion
Multiple independent legal and policy analyses of the proposed text (Ropes & Gray, Faegre Drinker, and the National Association of Counties among them) converge on describing a similar set of substantive changes, though as with any 400-plus-page proposed rule, the details worth checking against the actual Federal Register text before acting on them. The recurring themes in that commentary:
- Binding policy terms embedded in every award. The proposal would write current administration policy priorities — including restrictions on diversity, equity, and inclusion program activities — directly into the standard terms and conditions of federal awards, rather than leaving them to agency-specific implementation.
- Expanded termination authority. Commentary describes a broadened ability for awarding agencies to terminate awards mid-performance, beyond the termination-for-cause and termination-for-convenience provisions already in the current Uniform Guidance.
- New eligibility and verification conditions. Several summaries describe an E-Verify participation requirement extending to recipient organizations broadly, not only their federal contracting arms.
- Additional pre-issuance review. Industry commentary also describes added agency-level review steps before a discretionary award is issued.
Because this section draws on secondary legal analysis rather than a line-by-line reading of the Federal Register text, research administrators evaluating specific provisions should confirm exact language against the primary Federal Register document rather than relying on any single secondary summary, including this one.
Comment Period: Closed July 13, 2026 — What Happens Next
OMB set a 45-day comment window running from the May 29 publication date, closing July 13, 2026. Multiple sector associations, including higher-education and local-government groups, filed comments before the deadline, and secondary reporting describes a large volume of public comment overall — a figure worth confirming directly on the regulations.gov docket rather than repeated as a fixed number here, since it was still climbing as the deadline approached. As of this writing, OMB has not published a final rule. The standard next step under the rulemaking process is for OMB to review submitted comments, decide whether to revise the proposed text in response, and then issue a final rule (or, in principle, decline to finalize it, or extend the timeline) — none of which has been announced yet.
Effective Date: October 1, 2026, If Finalized on the Current Timeline
OMB has signaled an intent to have a final rule in place by October 1, 2026, the start of the federal fiscal year — the point at which changes to grant terms are administratively easiest to apply, since it lines up with when many agencies issue new awards and non-competing continuations. That date is not guaranteed: it depends on OMB completing comment review and publishing a final rule with enough lead time. Recipients should treat October 1, 2026 as the earliest realistic effective date, not a confirmed one, and watch for the final rule’s own effective-date language, which will govern rather than the proposal’s stated target.
How This Differs From What’s Already in Force
Nothing in the current, already-effective 2 CFR Part 200 has changed yet — the document published May 29 is a proposed rule, not a final one, and proposed rules have no legal effect on their own. CASRAI’s existing 2 CFR 200 content, including our guides to federal grant reporting requirements, subrecipient risk assessment before award, and FDP unilateral amendments for pass-through entities, along with our subrecipient risk assessment and 2 CFR 200 Subpart B dictionary entries, describes the regulation as it currently, actually operates. This piece exists specifically to track the proposed rewrite and its procedural status separately from that baseline — we’ll update it, or publish a follow-up, once OMB acts on the comments or issues a final rule. For related recent shifts in federal grant administration terms, see our coverage of NIH’s reversal of indirect-cost flexibilities.
What Research Administrators Should Do Now
- Do not assume any specific provision described in secondary commentary is final — it is still a proposal, and OMB retains full discretion to revise the text in response to comments before any final rule is issued.
- Track the docket directly (OMB-2026-0034) and the Federal Register docket page for the eventual final rule, rather than relying solely on secondary summaries.
- If a final rule is issued on or near the October 1, 2026 target, expect it to apply prospectively to new awards and amendments rather than retroactively rewriting terms on already-issued awards — confirm the final rule’s own applicability language once published, since this is a common but not universal pattern in Uniform Guidance revisions.
- Route this specifically to your institution’s grants and contracts office and general counsel; a reclassification of guidance into binding regulation, if finalized, changes both the substantive terms and the institution’s compliance exposure for non-adherence.
CASRAI will revisit this post as the rulemaking progresses. For the underlying framework this proposal would amend, see our broader grants management and research funding coverage.
