Navigating the government shutdown

Agencies will reopen and resume regulatory, enforcement and grant activities..

The IRS released an updated FY2026 Lapse Appropriations Contingency Plan, which outlines that 53.6% of the workforce will be contained during a lapse extending through April 30, 2026.

Tax filing deadlines remain unchanged.

Guidance for H.R. 1, P.L. 119-21, commonly known as OBBBA, could be delayed.

Potential delays in:

• Refund processing

• Audit, examination, and appeals activities

• Customer service response times

• Online account access and electronic payments

• Resolution for automated collection notices that continue during this period

View the IRS lapsed appropriations contingency plan for additional information.

The FASAB suspended operations. As a result, FASAB did not release guidance during the shutdown period.

The GAO suspended operations. As a result, GAO did not publish reports or update its website until operations resume.

Most GAO personnel were furloughed and unavailable, so calls and emails may not have been returned during this period.

Entities pursuing tax-exempt status may need to wait additional months for Forms 1023-EZ and 1023 to process.

Federal grant applications and approval processes were paused until the agency responsible for the grant has the authority and funding to return to regular operations.

Federal grants and contract reimbursements may be delayed or frozen.

The PCAOB is not funded through the appropriations process and was operational during the shutdown.

However, as all PCAOB rules must be approved by the SEC, formal action was likely to have been paused during the shutdown.

SEC functions that remained operational included:

• Certain services funded through government contracts, such as the EDGAR, IARD, and CRD systems.

• Public comments continued to be accepted but were not reviewed during the shutdown.

• A limited number of staff were on duty to handle emergency enforcement, litigation, examination, and market monitoring functions.

View the SEC lapsed appropriations contingency plan for additional information.

Social Security, Medicare, and Medicaid continued to make monthly payments, because the funds for these programs did not require annual appropriations.

Other services, such as benefit verifications, were paused with customer service delays expected.

The collection, processing, and publication of key economic data were halted making it more challenging for the Federal Reserve and other policymakers to assess the health of the U.S. economy.

Funding for key nutrition programs such as Supplemental Nutrition Assistance Program (SNAP) and Special Supplemental Nutrition Program for Women, Infants, and Children (WIC) are set to be funded through Sept. 30, 2026.

The Department of Commerce designated employees working on tariff-related issues (e.g., trade negotiations, implementation of existing tariffs) as essential. These employees continued to work during a shutdown.

During a shutdown, U.S. Customs and Border Protection continues to collect tariffs.

View Department of Commerce lapsed appropriations contingency plan for additional information.

Programs like Pell Grants, Federal Direct Loans, and FAFSA processing continued because they are funded through mandatory appropriations or carryover funds.

Borrowers continued making payments.

View the Department of Education lapsed appropriations contingency plan.

Grant processing and new awards were not processed.

Key HUD operations that support FHA-insured mortgages and Ginnie Mae’s work in the secondary mortgage market continued.

Monthly assistance programs, including Section 8 Housing Choice vouchers, public housing, and multi-family assistance contracts, continued to operate for as long as funding was available.

Most fair housing activities were paused.

Emergency shelters and transitional housing programs remained active.

The release of the Consumer Price Index (CPI) might have been directly impacted causing a delay in the official announcement of 2026 Medicare premiums, Social Security cost of living adjustments (COLA), retirement contribution limits, and other key benchmarks.

Compensation and benefits programs for which funding had not lapsed continued.

DOL continued to support states and other federal agencies in the administration and payment of unemployment insurance benefits.

View DOL lapsed appropriations contingency plan for additional information.

AICPA Experts Offer Advice to Help during Times of Financial Hardship and Job Loss, Oct. 20, 2025

AICPA Town Hall: Special Edition — Navigating the Government Shutdown, Oct. 16, 2025

Shutdown concerns, the quest for tax guidance, the future of IRS service, Oct. 8, 2025

AICPA Comment Letter on IRS Relief for Taxpayers Impacted by Ongoing Shutdown, Oct. 9, 2025

AICPA Renews Call to Except All IRS Employees for Duration of Shutdown, Oct. 3, 2025

AICPA Comment Letter Requesting IRS Contingency Plan for Possible Government Shutdown, Sept. 29, 2025

Not-for-Profit Government Shutdown Toolkit

Federal Funding Freezes Implications to NFPs and Other Entities

The Importance of Going Concern Evaluation for Nonprofits (NFP Section member access)

Risk Management Considerations for Nonprofits: Getting Started

Not-for-Profit Audit Environment | NFP Section Ideacast

NFP Hot Topics: KPIs, Liquidity, Operating Reserves, Going Concern | NFP Section webcast archive (NFP Section member access)

Government Shutdown & IRS Updates | Tax Section Odyssey

Client letter and FAQ for a government shutdown during tax season (Tax Section member access)