The main ARPA funds spending deadline for the Coronavirus State and Local Fiscal Recovery Funds program is December 31, 2026. Recipients generally needed to obligate those funds by December 31, 2024.
An important exception applies to funds used under the program’s Surface Transportation and Title I eligible-use categories, which had an expenditure deadline of September 30, 2026. Treasury’s current guidance confirms these dates.
However, there is no single deadline covering every program created by the American Rescue Plan Act. Application deadlines, spending periods, reporting dates, and closeout requirements depend on the particular award.
For governments, nonprofits, businesses, and contractors, the first step is to identify the funding program and the agreement governing the money.
What Are ARPA Funds?
ARPA stands for the American Rescue Plan Act, a federal law enacted to address the public health and economic effects of the COVID-19 pandemic.
The law supported multiple programs administered by different agencies. One of the largest was the Treasury Department’s Coronavirus State and Local Fiscal Recovery Funds program, commonly called SLFRF.
SLFRF delivered funding to state, territorial, local, and Tribal governments. Eligible uses included certain public services, pandemic-related assistance, infrastructure, and other authorized activities.
When a city or county refers to its “ARPA deadline,” it often means the SLFRF deadline. That terminology should not be applied automatically to education, housing, or other ARPA-funded programs.
ARPA Funds Deadline at a Glance
SLFRF recipients must distinguish between obligation, expenditure, reporting, and closeout deadlines. December 31, 2024, was the general deadline to incur qualifying obligations, while December 31, 2026, is the general deadline to expend properly obligated funds.
An earlier expenditure deadline of September 30, 2026, applied to the Surface Transportation and Title I eligible-use categories. Reporting follows each recipient’s assigned schedule and current Treasury instructions, while local agreements, final submissions, and closeout procedures may impose additional requirements. Reporting and closeout periods do not automatically extend the project spending deadline.
What Is the Difference Between Obligating and Spending Funds?
Understanding this distinction is essential.
Obligating Funds
An obligation generally involves an order, contract, subaward, or similar transaction that creates a requirement for payment. Treasury also recognizes certain other obligations under its program-specific rules.
Simply reserving money in a budget does not necessarily create a qualifying obligation. For example, a council resolution identifying a future project is different from an enforceable contract requiring payment for eligible work. Recipients should retain evidence establishing when the obligation arose, its amount, and the activities it covers.
Expending Funds
An expenditure concerns the use of funds to satisfy eligible costs. Having a valid obligation does not mean the recipient has finished spending the money.
A contract signed before the obligation deadline may still require work, invoicing, payment, and supporting documentation before the expenditure deadline. Recipients should apply Treasury’s definitions rather than assuming their internal accounting labels determine federal compliance.
Why the Difference Matters
The general obligation deadline has already passed. The remaining spending period does not create unrestricted authority to commit unused funds to new projects. Before charging a cost, confirm both its eligibility and its connection to a timely, valid obligation.
Which ARPA Spending Deadline Applies to Your Project?
For most SLFRF eligible uses, the expenditure deadline is December 31, 2026. Funds used under the Surface Transportation and Title I eligible-use categories had the earlier September deadline. Here, “Title I” refers to eligible activities associated with the Housing and Community Development Act framework, not the education program commonly called Title I.
The classification matters. A project’s general description alone may not establish which deadline applies.
For example, infrastructure work should be reviewed against its actual eligible-use category and award records. As of October 2026, the earlier deadline has passed. Recipients with affected balances should promptly reconcile expenditures and consult the applicable Treasury instructions.
What Happens to Unspent ARPA Funds?
Treasury states that recipients must return SLFRF funds that have not been expended by the applicable expenditure deadline.
A recipient should not assume that keeping money in a separate account, reserving it for a project, or transferring it to another organization satisfies the spending requirement.
A transfer to a subrecipient is not a general workaround for extending the federal deadline. The underlying use and award conditions still matter.
Unobligated Funds Require Separate Attention
Funds that were not validly obligated by the general obligation deadline present a different issue from funds that were obligated but remain unspent.
Treasury has emphasized that it is reviewing methods used to establish obligations and may recoup funds used contrary to program requirements.
Recipients should identify these balances separately and follow official return and correction procedures.
Can the ARPA Deadline Be Extended?
Do not assume an extension is available because a project is delayed. Construction problems, procurement difficulties, staffing shortages, or late invoices do not independently change the federal deadline.
A recipient should rely on an applicable legal change or authoritative written guidance before treating a different date as permissible.
An extension approved by a local project manager also cannot override the federal award’s limits.
Where completion is uncertain, determine which costs remain eligible for federal funding and whether another lawful funding source is needed.
Can You Change Projects After the Obligation Deadline?
Changes require careful review. A contract amendment, replacement agreement, budget adjustment, or reporting correction may have different consequences depending on the circumstances. Do not assume that money associated with a canceled project can freely move to an unrelated new project.
Before making a change, examine the original obligation, the reason for the change, and Treasury’s current rules governing amendments, replacements, and reclassification. A reporting adjustment cannot by itself create an obligation that did not exist on time.
Do Revenue Replacement Funds Have a Different Deadline?
Using the revenue replacement category does not generally remove the SLFRF obligation and expenditure deadlines. Revenue replacement can provide flexibility for eligible government services, but recipients must still establish compliant obligations, document expenditures, and meet reporting requirements.
A budget designation alone should not be treated as proof that funds were properly obligated or spent. Keep records showing the actual government services supported and how the reported amounts were determined.
What Deadlines Apply to Nonprofits and Businesses?
A nonprofit or business may receive assistance through an ARPA-funded local program rather than directly from Treasury. Its immediate deadlines usually appear in the application materials, grant agreement, contract, or program rules.
Subrecipients
A subrecipient carries out part of the funded program and may have monitoring, reporting, and expenditure responsibilities. The awarding government may set earlier deadlines so it has time to review costs and complete its own requirements.
Beneficiaries
A beneficiary receives assistance through an eligible program. Its responsibilities can differ from those of a subrecipient. The agreement should explain the permitted use, required evidence, and any deadlines.
Contractors
A contractor supplies goods or services under a procurement agreement. Contractual performance and invoicing dates matter, but the government must also determine whether the costs meet federal funding requirements. Being paid under an ARPA-funded contract does not make the contractor a direct federal grant recipient.
Can You Still Apply for ARPA Funds?
There is no universal open ARPA application. A local assistance program may have its own application window, eligibility rules, and available balance. The general federal spending deadline does not establish that new applications are being accepted.
Check the administering government’s current program page and confirm availability directly. For SLFRF, any remaining assistance must fit within the recipient’s valid obligations and applicable program rules. Avoid relying on an old announcement without confirming its status.
Reporting and Closeout Are Separate From Spending
Recipients may still have reporting work after project spending ends. A project is not necessarily closed because the account balance is zero. Treasury may require reconciliation, certifications, supporting information, and completion of its closeout process.
Treasury maintains a dedicated closeout resource hub, including instructions for recipients invited to begin closeout.
Confirm Your Reporting Schedule
Reporting requirements differ by recipient category. Use the current reporting guidance, portal instructions, and notices applicable to your award. Do not stop submitting required reports solely because all funds have been spent.
Retain Supporting Records
Organize contracts, procurement files, invoices, payment evidence, payroll records, subaward documents, and submitted reports. Follow the applicable retention requirements, including any longer period associated with an audit, dispute, or investigation. Administrative activity after the spending deadline does not automatically authorize additional project costs.
How to Prepare Before the Spending Deadline
Reconcile the Award
Compare the original award with valid obligations, recorded expenditures, remaining commitments, and cash balances. Investigate differences between accounting records and Treasury reports.
Review Every Open Project
Identify incomplete work, unpaid invoices, retainage, disputed charges, and expected credits. Determine what must happen before each applicable deadline.
Coordinate With Vendors and Subrecipients
Communicate required completion, invoicing, and documentation dates. Build in time for review and correction rather than relying on last-minute submissions.
Verify Eligibility
Deadline pressure does not make an otherwise ineligible expense allowable. Apply the same procurement, documentation, and cost-review standards used throughout the award.
Resolve Problems Early
Escalate uncertain obligations, delayed projects, and reporting discrepancies to the responsible finance, grants, and legal staff. Document decisions and obtain clarification where necessary.
Conclusion
For most SLFRF projects, the key spending deadline is December 31, 2026, following the obligation deadline that passed in December 2024. Surface Transportation and Title I eligible-use categories had an earlier expenditure deadline.
Recipients should reconcile remaining balances, verify the validity of obligations, complete eligible spending on time, and prepare for reporting and closeout. Businesses and nonprofits should also check their agreements, since local deadlines may be earlier than the federal program’s final date.
