The Micro-Purchase Threshold Is $15,000 as of October 1, 2025: What Changed for Grant Recipients

A $12,000 purchase and two different thresholds

A finance manager at a grant-funded nonprofit opens the organization's written procurement policy to approve a $12,000 equipment purchase. The policy says purchases up to $10,000 are micro-purchases and need no competitive quotes. Anything above that, under her organization's own policy, needs three quotes and a price comparison. (That count is a local rule; the federal text asks for quotes from "an adequate number of qualified sources.") She has just read that the federal figure changed, and the purchase order is dated after October 1, 2025.

Now she has to decide which number applies. It depends on the award, the policy, and whether anyone has recorded which rule the organization was following on the day it bought. A monitor reviewing the file a year from now will ask the same question. The answer needs to be in the file, not in someone's memory.

This article explains what changed with the micro-purchase threshold 2025 $15,000 adjustment, where 2 CFR Part 200 picks it up, and what a purchase file should record. After reading it, you should be able to show which threshold applied to a given purchase and why.

What the micro-purchase threshold 2025 $15,000 change says

The FAR Council's final rule, FAR Case 2024-001, raised the micro-purchase threshold from $10,000 to $15,000. It also raised the simplified acquisition threshold (SAT) from $250,000 to $350,000. Both changes took effect October 1, 2025. The rule was published August 27, 2025 at 90 FR 41872 (Doc. 2025-16412) as an inflation adjustment of acquisition-related thresholds.

The adjustment is routine. As the rule itself explains, statute requires acquisition-related thresholds to be adjusted for inflation every five years, and this was the 2025 round. The definitions live in FAR 48 CFR 2.101, and that is the section to cite when you describe the figure.

Grant recipients feel the change because 2 CFR 200.1 defines the micro-purchase threshold by reference to FAR 48 CFR part 2, subpart 2.1: generally, except as provided in 2 CFR 200.320, it is "not to exceed the amount set by the FAR" unless a higher threshold is approved. When the FAR figure moves, the federal reference point for recipients moves with it. Recipients do not read the FAR for its own sake. They read it because 2 CFR Part 200 points there.

The companion change to the SAT matters for the same reason. It sets the upper edge of simplified acquisition, which is covered in the article on the $350,000 simplified acquisition threshold.

Which awards the new figure reaches

The FAR definition changed on October 1, 2025: the eCFR text of 48 CFR 2.101 shows $10,000 through September 30, 2025 and $15,000 from October 1, 2025. How that change reaches a particular grant depends on the award and its terms, and organizations with federal grants have to work it into their own written procedures.

The effective date does not sort every purchase on your books. A nonprofit may hold a federal award made before October 1, 2025 and a second one made after it. The two awards may sit side by side in the same accounting system, and the awarding agency or pass-through entity may treat them differently. Confirm how the change applies to each specific award with the awarding agency or pass-through entity, and record the answer.

Two points to keep separate:

• The award and its terms determine which federal figure applies to that award.
• The date of the purchase is what anyone checking your file later has to reconstruct.

Record both. A purchase order dated November 2025 under an award made in 2024 is a different file from the same purchase under an award made in 2026, even if the dollar amount and the vendor are identical.

What 2 CFR 200 does with the FAR figure

2 CFR 200.320 sets out three types of procurement method: informal (micro-purchases and simplified acquisitions), formal (sealed bids or proposals) and noncompetitive. Micro-purchase sits in the informal group. The recipient's own policy decides how it operates day to day. The overview of 2 CFR 200.320 procurement methods walks through all three.

Recipients are not limited to the FAR figure. Under 2 CFR 200.320(a)(1)(iv), a recipient or subrecipient may self-certify a micro-purchase threshold up to $50,000 on an annual basis. The self-certification must include a justification, a clear identification of the threshold, and supporting documentation of one of the listed grounds: low-risk auditee status for the most recent audit, an annual internal institutional risk assessment, or, for public institutions, consistency with state law. The documentation must be available to the federal agency or pass-through entity and to auditors. Under 2 CFR 200.320(a)(1)(v), a threshold above $50,000 must be approved by the cognizant agency for indirect costs.

Local policy can also run the other way. Under 2 CFR 200.320(a)(1)(iii), the recipient is responsible for determining and documenting an appropriate micro-purchase threshold based on internal controls, an evaluation of risk and its documented procurement procedures, and that threshold must be authorized or not prohibited under state, local or tribal law. The SAT it adopts "may be lower than, but must not exceed, the threshold established in the FAR" (2 CFR 200.320(a)(2)(ii)). Many organizations set a micro-purchase figure below the federal maximum, and state or local rules may be stricter than the federal ones.

That leaves three numbers that could each be "the threshold" for a given purchase:

1. the FAR figure, now $15,000;
2. any higher figure the organization has self-certified under 2 CFR 200.320(a)(1);
3. the figure in the organization's written policy or in state or local rules, which may be lower.

The file should show which of the three controlled and where it came from.

What a micro-purchase still needs in the file

A micro-purchase is exempt from competitive quotations, not from judgment. Under 2 CFR 200.320(a)(1)(ii), micro-purchases may be awarded without soliciting competitive price or rate quotations if the recipient considers the price reasonable based on research, experience, purchase history or other information, and maintains documents to support that conclusion. The price basis has to be written down.

Under 2 CFR 200.320(a)(1)(i), recipients should also distribute micro-purchases equitably among qualified suppliers, to the extent practicable. A file full of $14,500 purchases from one vendor, none of them compared with anything, is hard to explain.

The micro-purchase method is not a way to skip procurement. That holds for software, subscriptions and workbooks the same as for equipment. Local policy may set a lower threshold, and a purchase split into pieces to stay under the line invites exactly the question a monitor will ask.

For purchases above the micro-purchase line, 2 CFR 200.318(i) requires records detailed enough to show the history of each procurement. They must include four elements:

• the rationale for the procurement method;
• the contract type selection;
• contractor selection or rejection;
• the basis for the contract price.

For a micro-purchase, "rationale for the method" can be a single line: the amount, the threshold relied on, and the reason the price was reasonable. For a purchase just above the line, it may need quotes and a comparison.

A worked example

This is a worked example with round inputs, not a real file. A nonprofit holds a federal award made in March 2026. Its written policy, last revised in 2023, sets the micro-purchase limit at $10,000. It has not self-certified a higher figure. It needs to buy $12,000 of program equipment in April 2026.

Under the FAR figure now in effect, $12,000 falls below $15,000. For this award, the federal definition would treat the purchase as a micro-purchase, assuming the awarding agency has not said otherwise. But the nonprofit's own written policy sets $10,000, and 2 CFR 200.320(a)(1)(iii) makes the documented threshold the recipient's own responsibility. So the purchase would still go through the organization's quote process unless the board or an authorized officer first revises the policy.

Three things should be in the file:

• the purchase amount and date;
• the threshold relied on ($10,000 from local policy, or $15,000 from 48 CFR 2.101 after the policy is revised), with the effective date of the revision;
• the quotes or price-reasonableness note that supports the amount.

If the policy had been updated first, the file would record the new policy date and the micro-purchase basis. Whichever route the organization takes, the file shows a choice made on the date, under a rule that can be named. If the file says only "under threshold," nobody reading it later can tell which rule it followed at the time.

What to record, and where to take it from here

Treat the threshold change as a policy-maintenance task with a dated paper trail. A short checklist:

• Read your own policy. Find every dollar figure that mirrors the FAR. Written procurement procedures under 2 CFR 200 should be consistent with 2 CFR 200.317–200.327, and a stale number is a visible inconsistency.
• Decide deliberately. Adopt $15,000, keep a lower figure, or document a self-certification up to $50,000. Record who decided and when.
• Stamp each purchase file with the threshold, its source and its effective date.
• Keep records through retention. 2 CFR 200.334 sets three years from the final financial report unless an exception applies, and local public-records rules may require longer.
• Watch for further change. OMB published a proposed rule, "Regulation for Federal Financial Assistance" (91 FR 32198), on May 29, 2026. As of October 2026 the Federal Register shows no final rule, so check federalregister.gov for its current status. Check the current FAR 2.101 text too, since 2 CFR picks up whatever figure it sets.

The procurement methods and thresholds chart puts the current figures in one place. The Small Purchase Quote Comparison Workbook is designed to record quotes side by side and the price-reasonableness note for a purchase. It is available now on its store page. To hear when the evaluation workspace opens, you can join the waitlist. RFPManagement's procurement-method selector is built to show the rule in force with its citation and effective date, and it is not yet published with live thresholds.

RFPManagement records and computes. It does not give legal or procurement advice. The award decision stays with your organization.