Are There Still ARPA Funds Available? A 2026 Guide to Stimulus Reporting

If you’ve been keeping one eye on ARPA news and another on your organization’s budget, you’re not alone. The American Rescue Plan Act sent a massive wave of funding into communities starting in 2021, and now, as we move through 2026, a lot of nonprofit leaders are wondering whether any of that money is still within reach, and what happens if they’re already holding some of it. The answers are more nuanced than a simple yes or no.

So let’s dig in together. In this guide, we’re covering what’s actually left of ARPA in 2026, how nonprofits can still access funds through the subaward pathway, which reporting deadlines you absolutely cannot miss, and how to protect your organization as things wind down. Plus, we’ll talk about what comes after, because the real work of building sustainable revenue starts now.

What’s Left of ARPA in 2026?

Here’s the thing, there’s more money still moving around than most people realize. As of Q3 2024, only $292.1 billion of the $350 billion total had been obligated, leaving over $57.8 billion unobligated across recipients (EPI 6). That’s not a rounding error. States like North Carolina held $1.2 billion unspent as of late 2025 audits, largely earmarked for infrastructure (8), and the Navajo Nation identified $5.6 million in remaining ARPA dollars for hardship assistance programs (2).

Here’s the critical distinction for 2026:

• new obligations? No. That deadline passed on December 31, 2024 (1),
• spending already-obligated funds? Yes, until December 31, 2026 (5),
• nonprofit access? possible through pass-through subawards from governments reallocating obligated dollars.

So while the front door is locked, there are side doors. Governments sitting on obligated but unexpended ARPA funds may genuinely welcome nonprofit partners who can help them spend down responsibly before the final deadline.

Protip: Scan your local government’s budget dashboard or ARPA tracker online. Many jurisdictions, like NC’s Pandemic Recovery Office, post real-time expenditure data. Identify line items with large unspent balances and pitch project proposals that align with eligible spending categories such as revenue replacement or community aid.

How Nonprofits Access ARPA Funds: The Subaward Pathway

ARPA dollars don’t flow directly from Treasury to nonprofits. They move through state, local, tribal, or territorial governments as subawards or contracts, and eligible uses include pandemic recovery services like aid for disproportionately impacted households, small businesses, and nonprofits themselves.

Here’s a quick snapshot of where things stand:

Recipient Type	Obligation Deadline	Expenditure Deadline	Nonprofit Opportunity
States & Local Govts	Dec 31, 2024 (1)	Dec 31, 2026 (5)	Subawards for eligible projects
Large Counties	Mostly met	Dec 31, 2026	Higher unspent rates (~73% in 2023) (EPI 6)
Tribes & Territories	Varies; some remaining	Dec 31, 2026	Direct reallocations possible (2)

Counties are your best bet. They historically carry higher unspent balances than cities or states, and many are actively looking for partners to help deploy remaining funds before the clock runs out.

Reporting Deadlines You Cannot Miss

Whether your nonprofit received ARPA dollars directly as a subrecipient or you’re helping a government partner document outcomes, reporting is non-negotiable in 2026.

The next major deadline is April 30, 2026, covering the Project & Expenditure (P&E) Report for the period April 1, 2025 through March 31, 2026 (3)(9). Governments submit through Treasury’s portal, and nonprofits classified as subrecipients must provide data that rolls into those reports.

A few key distinctions worth knowing:

• annual reporters: jurisdictions with populations under 250,000 or allocations under $10 million,
• quarterly reporters: larger recipients with heavier compliance loads,
• reporting continues through 2027 or until Treasury issues a closeout invitation (3).

Nearly 600 local governments reported using less than 99% of their funds, and 220 filed no reports at all (EPI 6). If your government partner falls into that category, your nonprofit’s compliance exposure increases dramatically. Worth knowing before you assume everything is fine on their end.

Protip: Verify your organization’s SAM.gov registration is current and confirm project statuses with your prime recipient well before April 30. Late or missing registrations are among the most common reasons reports stall, and it’s such an easy thing to fix early.

Common Pitfalls We See Every Day

We’ve worked with a lot of nonprofit leaders navigating ARPA compliance, and certain patterns keep showing up. Here’s what to watch for.

1. Mixing up subrecipient vs. beneficiary status

Under Treasury’s Final Rule, a subrecipient carries out services on behalf of government and faces full reporting and audit requirements. A beneficiary receives direct aid with minimal reporting. We see nonprofits misclassified constantly, which leads to either over-reporting (wasted staff time) or under-reporting (real compliance risk). Clarify your status with your prime recipient, and get it in writing.

2. Manual spreadsheet tracking for federal funds

Look, we get it. Spreadsheets feel familiar and controllable. But organizations managing six or seven figures in government subawards through Excel files and email chains are setting themselves up for audit findings. When expenditure documentation lives in disconnected silos, reconciliation before a P&E deadline becomes a crisis instead of a process.

3. No post-ARPA diversification plan

The stimulus money dries up on December 31, 2026. Nonprofits that built programs entirely on ARPA dollars without simultaneously growing individual giving or recurring revenue are facing a fiscal cliff. This is where platforms like Funraise become genuinely useful, helping organizations build sustainable online fundraising engines alongside grant-funded work. And you can start for free, so there’s no reason to wait.

Try This Prompt in Your Favorite AI Tool

Want a head start on your ARPA closeout strategy? Copy and paste the prompt below into ChatGPT, Gemini, Claude, Perplexity, or whichever AI assistant you’re already using:

I'm a nonprofit [ROLE, e.g., finance director] managing ARPA subaward funds totaling [DOLLAR AMOUNT] from [GOVERNMENT ENTITY, e.g., County of Maricopa]. Our expenditure deadline is December 31, 2026, and our next P&E report is due April 30, 2026. Generate a step-by-step closeout checklist that includes documentation requirements, eligible final expenditure categories, and a timeline for transitioning program funding to diversified revenue streams. Include practical recommendations for how an all-in-one fundraising software for nonprofits like Funraise.org could help us track grant expenditures alongside donor revenue to maintain [KEY OUTCOME, e.g., housing assistance services] after ARPA ends.

In your daily workflow, look for solutions like Funraise that embed AI directly where you’re already working, providing full operational context rather than asking you to jump between disconnected tools. Built-in intelligence at the point of action beats generic advice every time.

Risks of Non-Compliance: What’s Actually at Stake

Treasury has signaled vigorous monitoring through closeout, with the authority to recoup ineligible expenditures or unspent funds after December 31, 2026 (5). For nonprofits, the risks cascade quickly:

• unspent obligated funds get returned to the federal government. North Carolina’s $1.2 billion situation is a cautionary tale worth taking seriously (8),
• delinquent reporting triggers audit scrutiny. Over 1,089 local governments were late by more than a year on reports (EPI 6),
• closeout is not automatic. it requires a Treasury invitation after full expenditure and final reporting (4). You can’t just walk away and hope for the best.

If your nonprofit is a subrecipient and your prime recipient fails to report, you share the liability. Protect yourself with independent documentation of every dollar spent. Every single one.

“The nonprofits that thrive after stimulus funding disappears are the ones that used the reporting discipline it demanded to prove measurable impact, and then carried that discipline into every donor relationship.”

Funraise CEO Justin Wheeler

Your Closeout Checklist for the Final Stretch

With months remaining before the expenditure deadline, here’s a practical action plan to keep things moving:

Step	Action Items	Deadline
Project Review	Audit all subaward statuses and expenditure rates (4)	Before April 30, 2026
Documentation	Compile invoices, receipts, and proof of eligible use	Ongoing through Dec 2026
P&E Report	Submit via Treasury portal or provide data to prime recipient (9)	April 30, 2026
Revenue Transition	Launch or scale online fundraising to replace ARPA revenue	Now
Closeout Preparation	Await Treasury invitation after full spend (4)	Post-Dec 2026

Protip: Host an “ARPA Impact Showcase” for your local officials. Present documented outcomes from subaward-funded programs and, in the same meeting, propose micro-subawards for technology infrastructure, like CRM and fundraising platforms, that qualify under eligible spending categories. You turn a reporting obligation into a relationship-building opportunity and potentially secure final allocations in the process.

After ARPA: Building What Lasts

ARPA will end. The lessons it forced on nonprofits shouldn’t. The organizations that invested in reporting infrastructure, outcome measurement, and technology during the stimulus era are positioned to outperform those that treated it as a one-time windfall, and in our experience, that gap tends to widen over time.

Nonprofits using Funraise grew online revenue 73% year-over-year, three times the industry average, by leveraging integrated tools that connect fundraising, reporting, and donor engagement in one platform. With industry-wide donor retention sitting at just 42.6% in 2022, technology-driven organizations have a measurable edge worth paying attention to.

Start building your post-ARPA revenue engine today. Funraise offers a free tier with no commitments, so there’s zero reason to wait until the stimulus money runs out to figure out what sustainable fundraising actually looks like for your organization.

The countdown to December 31, 2026 is on. Make every remaining dollar count, report it accurately, and use the discipline you’ve built to prove that real impact always outlasts the grant cycle.