Two professionals review information on a tablet and document while discussing updates for state and local government financial reporting and compliance.

Q2 2026: Federal Assistance, Data Transparency, and More

8/13/2026

Get updates on developments that might affect state and local government financial reporting, compliance posture, operational risk, and governance oversight.

Message from Tony Boras, partner, national office

Welcome to the second quarter 2026 issue of the State and Local Government Executive Briefing.

As state and local governments move into the second half of 2026, finance, audit, and governance leaders continue to operate in an environment defined by evolving accounting standards, changing federal award requirements, expanded reporting obligations, and increased expectations for transparency and oversight.

This quarter’s briefing highlights developments related to governmental GAAP research and standard-setting activity, proposed changes to federal financial assistance requirements, IRS access and filing updates relevant to governmental entities, continued implementation of federal data transparency initiatives, grant reporting and reimbursement matters, and audit and internal audit developments related to cash confirmations and anti-corruption risk.

Our objective with this quarterly publication is to provide state and local government leaders – including finance directors, governing officials, internal auditors, and administrative executives – with a concise update on developments that might affect financial reporting, compliance posture, operational risk, and governance oversight in the months ahead.

We hope you find this briefing informative and welcome your feedback as we continue to refine future editions.

From the GASB

GASB current standard-setting project forecast

Project Expected date
Q3 26 Q4 26 Q1 27 Q2 27 Q3 27 Q4 27 Q1 28 Q2 28
Implementation Guidance Update – 2026 Final
Infrastructure Assets Final
Going Concern Uncertainties and Severe Financial Stress Exposure draft Final
Revenue and Expense Recognition Exposure draft 1
Voluntary Digital Financial Reporting Discussion memorandum
GAAP Structure Final

Based on the GASB technical plan for the second third of 2026.

GASB seeks feedback on structure used to communicate governmental GAAP

In April 2026, the Governmental Accounting Standards Board (GASB) issued a discussion memorandum, “The Structure for Communicating Generally Accepted Accounting Principles for State and Local Governments,” seeking feedback on potential changes to the organization and accessibility of governmental accounting guidance. The discussion memorandum is part of GASB’s pre-agenda research and is not a proposed accounting standard. Comments are due Aug. 31, 2026.

The research focuses on GASB’s current “dual-authority” approach, under which both original pronouncements and the GASB Codification have authoritative status, and explores whether a single-authority structure could be operationalized. Although this project would not result in immediate financial statement changes, it could affect how preparers, auditors, and users access, research, cite, and apply governmental GAAP in future periods.

GASB updates technical plan for the second third of 2026

The GASB released its technical plan for the second third of 2026, which provides updated expected milestones for standard-setting projects, technology initiatives, pre-agenda research, monitoring activities, and post-implementation review activities.

One notable change in the technical plan is that digital assets moved from monitoring into pre-agenda research. GASB staff is expected to review literature, conduct outreach with state and local governments, and review Annual Comprehensive Financial Reports (ACFRs) to understand if and how digital asset information is currently reported or disclosed. That research remains early stage and does not yet represent a proposed standard-setting project.

Another notable update is the removal of cybersecurity risk disclosures from the active research agenda. In May 2026, the GASB decided not to add a project on information about cybersecurity to the current technical agenda. Cybersecurity remains an important governance, operational, internal control, and risk oversight matter for governments, but governments should not expect a standalone GASB cybersecurity disclosure proposal on the current agenda at this time.

FAF announces GASB board updates

During the second quarter, the Financial Accounting Foundation (FAF) Board of Trustees announced a search for a new GASB member to fill a seat that opens July 1, 2027, when Kristopher E. Knight completes his second term. The FAF indicated that it is seeking an individual with substantial experience as a preparer of state government financial statements or as a public accountant with a practice emphasis in state and local government accounting and auditing.

In a separate board update, the FAF appointed Jacqueline L. Reck to serve a one-year term as vice chair of the GASB. Her appointment became effective July 1, 2026. Reck succeeds Jeffrey J. Previdi, who completed his service to the board on June 30, 2026. Reck has served as a GASB member since 2022 and was reappointed in 2025 to a second term that concludes June 30, 2032.

Upcoming GASB statement effective dates

GASB statement Effective dates –
periods beginning after
Early adoption
Certain Risk Disclosures (GASB Statement 102)
Provides users of government financial statements with essential information about risks related to a government's vulnerabilities due to certain concentrations or constraints.

This statement requires a government to assess whether a concentration or constraint makes the government vulnerable to the risk of a substantial impact. It also requires governments to assess whether events associated with that concentration or constraint have occurred, begun to occur, or are more likely than not to occur within 12 months of the financial statement issuance date. If these criteria are met, the statement requires disclosures that help users understand the nature of the concentration or constraint and the government's vulnerability.
June 15, 2024 Permitted
Financial Reporting Model Improvements (GASB Statement 103)
Improves key areas of the current financial reporting model, including enhancements to management's discussion and analysis (MD&A), presentation of proprietary fund statements, budgetary comparison information, reporting of unusual or infrequent items, presentation of major component unit information, and other application issues.
June 15, 2025 Permitted
Disclosure of Certain Capital Assets (GASB Statement 104)
Requires certain types of capital assets to be disclosed separately in the capital assets note disclosures and establishes requirements for capital assets held for sale, including additional disclosure requirements.
June 15, 2025 Permitted
Subsequent Events (GASB Statement 105)
Clarifies the definition and evaluation period for subsequent events, distinguishes recognized from nonrecognized events, and establishes disclosure requirements for certain nonrecognized subsequent events.
June 15, 2026 Permitted
From the federal government

Federal agencies extend web and mobile accessibility compliance dates

During the second quarter, the U.S. Department of Justice (DOJ) and the U.S. Department of Health and Human Services (HHS) extended certain web content and mobile application accessibility compliance dates by one year.

For state and local governments subject to the Title II rule of the Americans with Disabilities Act, the DOJ extended the compliance date for public entities with a total population of 50,000 or more from April 24, 2026, to April 26, 2027. Public entities with a total population of less than 50,000 and special district governments now have until April 26, 2028. The extension applies to the web and mobile app accessibility requirements adopted by the DOJ in 2024.

HHS also extended compliance dates under Section 504 of the Rehabilitation Act for recipients of HHS federal financial assistance. Recipients with 15 or more employees now have until May 11, 2027, and recipients with fewer than 15 employees now have until May 10, 2028.

OMB and federal agencies propose revisions to federal financial assistance rules

On May 29, 2026, the Office of Management and Budget (OMB) and numerous federal grant-making agencies issued a proposed rule, “Regulation for Federal Financial Assistance,” that would revise governmentwide requirements for grants, cooperative agreements, and other forms of federal financial assistance. The comment period closed July 13, 2026.

The proposal is broad and would affect several areas relevant to recipients and pass-through entities, including notices of funding opportunities, merit review processes, internal control expectations, cybersecurity safeguards, mandatory disclosures, fixed amount awards and subawards, payment controls, and other federal award administration requirements. Among the notable proposed changes, fixed amount awards and fixed amount subawards would not be permitted unless authorized by federal statute. Federal agencies also would be required to use clearer summary information in notices of funding opportunities, generally make opportunities available for at least 60 calendar days, and use plain language in funding announcements.

One proposed change that could be especially significant for recipients and subrecipients is a new E-Verify requirement. The proposed rule would require recipients and subrecipients to participate in the Department of Homeland Security’s E-Verify program to confirm the employment eligibility of employees and contractors hired in, or performing work in, the United States under a federal award. Recipients and subrecipients also would be required to notify the federal agency or pass-through entity if they receive a final nonconfirmation notice through E-Verify.

IRS expands Business Tax Account access to government and tax-exempt entities

The IRS announced on April 6, 2026, that it expanded Business Tax Account access to partnerships, federal, state, and local governments, Indian tribal governments, and tax-exempt organizations. The Business Tax Account is a secure online platform that allows eligible users and designated officials to view tax balances, make payments, review payment history, download select digital notices, view eligible transcripts such as payroll and income transcripts, request tax compliance checks, and view the business name and address on file with the IRS. For governmental entities, this expansion could provide a more efficient way to access federal tax information and manage certain IRS interactions.

Federal data transparency developments continue under the FDTA

On June 8, 2026, the SEC announced a final joint rule establishing data standards under the Financial Data Transparency Act (FDTA). The standards are intended to promote interoperability of financial regulatory data across covered agencies through common identifiers for entities, geographic locations, dates, and certain products and currencies, as well as principles-based standards for data transmission, schema, and taxonomy formats. The SEC’s rulemaking page states that the joint rule is effective Oct. 1, 2026, but that it will not change reporting requirements without further agency action.

GAO report examines path toward governmentwide regulatory reporting standards

On May 14, 2026, the Government Accountability Office (GAO) issued a report required by the FDTA on the feasibility, costs, and potential benefits of building toward a broader governmentwide regulatory reporting model similar to Standard Business Reporting. GAO reported that standardized and interoperable data could improve regulatory analysis, oversight, and reporting efficiency, but also noted potential challenges and costs related to legacy system modernization, interagency coordination, data governance, reporting-entity system changes, and testing. GAO also observed that practitioners said the FDTA could put the United States on a path toward a governmentwide reporting system similar to Standard Business Reporting, although additional reforms and adoption would be necessary.

Clean energy tax credit deadlines affect governmental entities

Governmental entities with clean energy projects should evaluate whether they have met the filing and project timing requirements needed to claim federal clean energy credits through elective pay, also referred to as direct pay.

On May 14, 2026, the IRS reminded federal, state, and local government entities filing Form 990-T to make an elective payment election that Form 8868 may be used to request an automatic six-month filing extension. For calendar-year entities with 2025 projects, the original Form 990-T due date was May 15, 2026; if properly extended, the due date generally is Nov. 16, 2026, because Nov. 15 falls on a Sunday.

Government officials also should note that several project-related dates recently passed. The IRS states that the Section 30C alternative fuel vehicle refueling property credit applies to eligible property placed in service through June 30, 2026, and IRS instructions for the clean electricity production credit indicate that applicable wind and solar facilities generally must have begun construction on or before July 4, 2026, or be placed in service before 2028.

Treasury releases updated SLFRF reporting guide as expenditure deadlines approach

The U.S. Department of the Treasury released an updated July 2026 Project and Expenditure Report User Guide on July 1, 2026, for the Q2 2026 State and Local Fiscal Recovery Funds (SLFRF) reporting cycle. The guide states that there are no notable system changes for the Q2 reporting cycle. For recipients required to submit quarterly Project and Expenditure Reports, Q2 2026 reports are due July 31, 2026.

Recipients also should keep closeout and expenditure deadlines in mind. Treasury recently reminded recipients that SLFRF funds generally must be expended by Dec. 31, 2026, except for Surface Transportation and Title I projects, for which funds must be expended by Sept. 30, 2026. Recipients are required to return SLFRF funds that have not been expended by the applicable deadline. Recipients that have fully expended their SLFRF allocation should continue submitting Project and Expenditure Reports unless and until Treasury notifies them that they have been invited to close out their SLFRF award.

FEMA required to create public disaster reimbursement dashboard

H.R.7147, the Homeland Security and Further Additional Continuing Appropriations Act, 2026, enacted April 30, 2026, includes a new Federal Emergency Management Agency (FEMA) disaster reimbursement transparency requirement. Section 313 of the law requires FEMA to post an interactive dashboard on its public-facing website with reimbursement requests for covered individual assistance and public assistance expenses related to emergency and major disaster declarations under the Stafford Act. The dashboard is expected to include information such as damage category code, cost estimates, applicant ID, submission dates, project descriptions, federal and nonfederal cost share, FEMA review and approval status, project-level progress updates, and explanations for certain delays or denials. The law requires the information to be posted within 90 days after FEMA receives it and within 60 days after the information is under final review by the U.S. Department of Homeland Security. For governments seeking FEMA reimbursement, the dashboard could provide additional visibility into reimbursement status and timing.

From the AICPA

AICPA updates auditing standards for external confirmations

On May 14, 2026, the American Institute of CPAs (AICPA) Auditing Standards Board approved a new Statement on Auditing Standards (SAS) on External Confirmations. The new SAS introduces a requirement for auditors to use external confirmation procedures for cash and cash equivalents held by third parties unless certain conditions exist. It also updates guidance for the use of intermediaries in the confirmation process, negative confirmations, and situations in which auditors directly access information maintained by a knowledgeable external source.

The new SAS will be effective Dec. 15, 2028, with early adoption permitted. For state and local governments, the standard could affect future audit procedures over bank accounts, pooled cash, custodial accounts, investment accounts, fiscal agents, bond trustees, and other third-party cash or cash-equivalent arrangements.

From The IIA

IIA seeks feedback on draft Anti-Corruption Topical Requirement

The Institute of Internal Auditors (IIA) released a draft Anti-Corruption Topical Requirement for public comment. The draft focuses on governance, corruption risk assessment, third-party risk, whistleblower mechanisms, training, monitoring, and the design and effectiveness of anti-corruption controls. It also outlines auditor expectations for evaluating how organizations prevent, detect, and respond to corruption risks. Topical Requirements are a mandatory component of the International Professional Practices Framework and apply when internal auditors provide assurance services on a covered topic.

For governments, the draft may be relevant to internal audit activities involving procurement, grants management, third-party relationships, ethics and compliance programs, fraud risk management, hotline or whistleblower processes, and other areas with elevated corruption risk. Comments were due July 23, 2026.

Portions of AICPA materials reprinted with permission. Copyright 2026 by AICPA.

GASB materials reprinted with permission. Copyright 2026 by Financial Accounting Foundation, Norwalk, Connecticut. Copyright 1974-1980 by American Institute of Certified Public Accountants. Copyright 1976-1984 by Government Finance Officers Association.

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Tony Boras
Tony Boras
Partner, National Office

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