ARPA Reporting Requirements: 2026 Calendar, Portal Filing, and Closeout

ARPA reporting requirements for the Coronavirus State and Local Fiscal Recovery Funds come down to one document filed through Treasury’s portal: the Project and Expenditure Report. You file it quarterly or annually depending on your tier, you tag every dollar to one of Treasury’s expenditure categories, and you do all of this against a hard expenditure deadline of December 31, 2026.¹ What follows is what to file, when, and what the portal expects to see.

Who Files and How Often

Treasury places every recipient in one of five reporting tiers based on population and total SLFRF allocation. Your tier is visible in the reporting portal.²

Tier 1, quarterly: states, U.S. territories, and metropolitan cities and counties over 250,000 residents.
Tier 2, quarterly: metropolitan cities, counties, and non-entitlement units under 250,000 that received more than $10 million.
Tier 3, quarterly: tribal governments that received more than $30 million.
Tier 4, annually: tribal governments that received less than $30 million.
Tier 5, annually: metropolitan cities, counties, and non-entitlement units under 250,000 that received less than $10 million.

The tier reflects your total allocation across all sources, not what you have drawn down or spent so far. If your jurisdiction receives funds through more than one entity type, Treasury combines those allocations to set the tier.²

Non-entitlement units receive their funds through the state rather than directly from Treasury, but each one still carries its own reporting obligation on the tier schedule above.³

The 2026 Filing Calendar

Both quarterly and annual filers share the same first 2026 deadline: April 30, 2026. For quarterly filers that submission covers January through March. For annual filers it covers all of the preceding calendar year.⁴ Quarterly filers then report by the last day of the month after each quarter: July 31 for Q2, October 31 for Q3, and January 31 for Q4.

Two program-wide dates sit behind that calendar. The obligation deadline already passed on December 31, 2024, so all funds should be committed through contracts, subawards, or other binding agreements. The expenditure deadline is December 31, 2026, by which point obligated funds must be fully spent.¹ Surface transportation projects and Housing and Community Development Act Title I projects have an earlier expenditure deadline of September 30, 2026.

The separate Recovery Plan Performance Report that Tier 1 recipients used to file each July is no longer required for filings due in 2025 and beyond.⁵

What Goes Into the Project and Expenditure Report

The Project and Expenditure Report is the primary compliance document. It tracks every project funded with SLFRF dollars, including obligations, expenditures, and subawards. Each project gets a unique Project ID and must be assigned one of Treasury’s Expenditure Categories, grouped into seven major buckets:⁵

EC 1, Public Health: vaccination, testing, contact tracing, mental health services, substance use treatment, and related public health spending.
EC 2, Negative Economic Impacts: household assistance for rent, food, and utilities, job training, aid to impacted industries, and childcare support.
EC 3, Public Sector Capacity: payroll and benefits for public health and safety workers, rehiring staff, and improving service delivery.
EC 4, Premium Pay: hazard or premium pay for essential public and private sector workers.
EC 5, Infrastructure: water, sewer, and broadband projects, including drinking water treatment and lead remediation.
EC 6, Revenue Loss: government services funded through the revenue loss provision.
EC 7, Administrative: administrative costs and transfers to other units of government.

Each project is tagged with a decimal-coded subcategory. For example, 1.1 is COVID-19 Vaccination and 5.11 is Drinking Water Transmission and Distribution. Along with the code you need a clear project description explaining how the spending meets SLFRF eligibility criteria, plus dollar amounts for obligations and cumulative expenditures.

The Revenue Loss Standard Allowance Trap

A commonly used provision lets recipients claim up to $10 million in revenue loss (or their total award, whichever is less) and spend those funds on general government services without calculating actual revenue losses. Electing the standard allowance does not, by itself, satisfy the obligation requirement. You still need to obligate funds to specific projects, report them under EC 6, enter an obligation dollar amount for each project, and write a sufficient project description. Moving money into a general fund does not count as an obligation, and neither does an adopted budget, appropriation, or resolution that lacks a binding commitment behind it.⁶ Funds left in EC 6 without proper obligation entries will show as unobligated in the portal.

Filing Through Treasury’s Portal

Before you can file, your organization needs a Unique Entity Identifier through SAM.gov. The UEI is a 12-character alphanumeric code that replaced the DUNS number for federal award tracking.⁷ Every recipient must have a UEI and an active SAM.gov registration before receiving a federal award, and your taxpayer ID and legal name in SAM.gov must match IRS records.⁸

Each person needing portal access creates an account through either Login.gov or ID.me.⁹ Login.gov users can reach the compliance reporting sections; ID.me users can also reach applications and application information.¹⁰ For 2026 reporting purposes, Login.gov is sufficient for most users.

Inside the portal you pick the report type for your tier. You can upload completed Excel or PDF templates from Treasury’s compliance page or enter data directly into the web forms. The portal runs validation checks for formatting errors before you can advance. A designated authorized representative then digitally certifies the submission. Save the confirmation screen and tracking number the portal generates.

What Has to Sit Behind the Numbers

Federal regulations require every SLFRF recipient to establish, document, and maintain effective internal controls over the award, providing reasonable assurance that funds are being managed in compliance with the law and the terms of the award.¹¹ In practice that means written policies for procurement, conflict of interest, and financial management; segregation of duties; regular reconciliation between your accounting system and what you enter in the portal; and cybersecurity measures for personally identifiable information. Auditors look at conflict-of-interest documentation early, especially for infrastructure work involving outside contractors.

All financial records and supporting documentation must be kept for five years after all funds have been expended or returned to Treasury, whichever comes later. For subrecipients the clock starts when they submit their final expenditure report to the pass-through entity. Every dollar should trace back to a specific invoice, payroll record, or contract.

Single Audit and the Alternative

Any organization that spends $1 million or more in total federal awards during its fiscal year must undergo a Single Audit (or a program-specific audit) under 2 CFR 200, Subpart F. SLFRF spending counts toward that threshold. Organizations below the threshold are exempt from federal audit requirements, though their records must still be available for review by the federal agency, the pass-through entity, or the Government Accountability Office.¹²

Treasury also offers a lighter option called the Alternative Compliance Examination Engagement. You qualify if your total SLFRF award (direct or as a non-entitlement unit) is $10 million or less and your other federal award expenditures are below $750,000 during the fiscal year.¹³ Instead of a full Single Audit, you engage an independent practitioner to perform a compliance examination under GAO Government Auditing Standards and AICPA attestation standards. You can always elect a full Single Audit instead.

If You Passed Funds Through to Others

If you made a subaward of SLFRF funds, you became a pass-through entity with real oversight duties. Before making the award you must verify in SAM.gov that the subrecipient is not suspended, debarred, or otherwise excluded.¹⁴

Every subaward must be clearly identified as such and carry specific data: the subrecipient’s name matching their UEI registration, the Federal Award Identification Number, the subaward period of performance and budget period, the amount of federal funds obligated, and the project description required under the Federal Funding Accountability and Transparency Act.¹⁴ Missing any of these elements is a recurring audit finding. Beyond the paperwork, pass-through entities must actively monitor subrecipient performance and compliance across the award period, including reviewing their financial and programmatic reports and following up on any deficiencies.

Closing Out the Award

The SLFRF period of performance ends December 31, 2026, and unspent funds must be returned to Treasury. Closeout is Treasury-initiated. You wait for an invitation through the portal; if you have not received one, closeout is not yet available for your jurisdiction.¹

Once invited, you initiate closeout through the Closeout Reports section of the portal. Your last submitted Project and Expenditure Report serves as the final report. If the pre-populated data in the SF-425 form under the closeout tab is inaccurate, you must go back and revise your latest P&E Report, update the obligation and expenditure fields, provide a written justification for the changes, resubmit, and then return to initiate closeout again.¹ The final step is a closeout certification in the portal.

After Treasury accepts your closeout, you are generally exempt from further quarterly or annual P&E reporting. Recipients invited to close out who do not finish the process must keep filing until Treasury re-invites them, and may face additional oversight. Under the general federal closeout rule, recipients must submit all final reports within 120 calendar days after the period of performance ends and must liquidate all financial obligations within the same window.¹⁵ Any unobligated funds Treasury has paid must be refunded promptly.

What Happens If You Miss a Deadline

A late or inaccurate report can trigger a range of federal remedies. Under the Uniform Guidance, Treasury or a pass-through entity can temporarily withhold payments until the recipient corrects the problem, disallow costs tied to the noncompliant activity, or suspend or terminate the award.¹⁶ In more serious cases the federal agency can initiate debarment proceedings or withhold funding for other federal programs.

In practice, Treasury monitors the portal for late filings and issues notices of noncompliance. For smaller jurisdictions the most common consequence is a hold on remaining fund disbursements until the delinquent report is submitted. The stakes rise sharply if the problem is misuse rather than lateness: recapture of the full award amount is on the table when spending falls outside eligible categories. With the program winding down in 2026, recipients still behind on reports have a shrinking window to get compliant before closeout locks the deficiencies in.

1
U.S. Department of the Treasury. SLFRF Closeout Process Overview Resource
2
U.S. Department of the Treasury. Project and Expenditure Report User Guide
3
U.S. Department of the Treasury. Coronavirus State and Local Fiscal Recovery Funds for Non-entitlement Units of Local Government
4
U.S. Department of the Treasury. Reporting and Compliance
5
U.S. Department of the Treasury. Coronavirus State and Local Fiscal Recovery Funds Compliance and Reporting Guidance
6
U.S. Department of the Treasury. Quick Reference Guide: Using SLFRF Funds to Replace Lost Revenue and Provide Government Services
7
General Services Administration. Unique Entity ID (SAM) Frequently Asked Questions
8
eCFR. 2 CFR Part 25 – Unique Entity Identifier and System for Award Management
9
U.S. Department of the Treasury. SLFRF Treasury Portal Account Access Help – Best Practices and Common Fixes
10
U.S. Department of the Treasury. SLFRF Self-Service Resources
11
eCFR. 2 CFR 200.303 – Internal Controls
12
eCFR. 2 CFR 200.501 – Audit Requirements
13
U.S. Department of the Treasury. Alternative Compliance Examination Engagement Report User Guide
14
eCFR. 2 CFR 200.332 – Requirements for Pass-Through Entities
15
eCFR. 2 CFR 200.344 – Closeout
16
eCFR. 2 CFR 200.339 – Remedies for Noncompliance