The purpose of COA is to encourage and assist state and local governments to go beyond the minimum requirements of generally accepted accounting principles to prepare annual comprehensive financial reports (ACFRs) that evidence the spirit of transparency and full disclosure, and then to recognize individual governments that succeed in achieving that goal.
For financial reporting to be effective, the information in the reports must be: understandable, reliable, relevant, timely, consistent, and comparable. (1) The COA program requirements incorporate each of these characteristics. The characteristic of timeliness is incorporated by requiring submission of applications and annual comprehensive financial reports (ACFRs) within six months of the end of the fiscal year covered by the ACFR.
Our policy has been that governments could apply for an extension of one month under extenuating circumstances, which would be awarded by staff based on the explanation provided. In certain cases, governments were permitted additional one-month extensions, up to a total of six extensions for a single year, if circumstances warranted. Extension requests submitted twelve months or more following a government’s fiscal year end required approval of the COA Special Review Executive Committee (SREC). Extension requests that noted the same reason as the prior year, regardless of whether they were within twelve months after the government’s fiscal year end, also required approval of the SREC.
While timely financial information remains a key component of excellence in financial reporting and COA program policy, our current policy does not reflect this. Therefore, we will add comparative timeliness information on award certificates and revise our extension policy as follows.
New Policy
Effective for extension requests submitted on or after January 1, 2026, the following policy will be uniformly enforced:
Deadline:
1. The deadline for submission to the COA is six calendar months after the end of the fiscal year for which the ACFR is prepared.
Extensions for hardships and failures to submit a timely application:
2. Governments that require more than six months to complete their ACFR must submit an extension request, including the reason the extension is needed.
Extensions will be granted in one-month increments. Staff may not grant more than a total of six, one-month extensions to a government for the same fiscal year’s application (i.e., the final extension period sought may end up to maximum of six calendar months beyond the program’s usual submission deadline, which would be up to one year after the end of the fiscal year covered by the ACFR).
3. If a government can demonstrate that their eligible ACFR was made publicly available within six months after FYE, but that they simply failed to make a timely submission of their COA application, they may apply for an extension following the same guidelines as for governments that experience hardships, as put forth in item 2, above.
Appeals
4. Governments may appeal to the SREC for extensions if the government experiences extraordinary circumstances that they believe outweigh the negative effects of delay on the essential characteristic of timeliness of financial reporting and therefore seek an extension totaling more than six months for a single year for hardship(s).
To submit an appeal to the SREC, once your ACFR is completed, please send an email to coaprogram@gfoa.org detailing the circumstances that led to the delay and why the additional time was needed. The SREC meets monthly to consider appeals.
Criteria that will be used in granting or denying extension appeals may include, but are not limited to the following:
The extent to which the cause of the delay was within or outside of the control of the government,
The extent to which the cause of the delay was or was not reasonably foreseeable by the government,
The frequency of extensions granted to this government in recent prior years, if any, and
The number of extensions previously issued for the same fiscal year, if any.
(1) The Governmental Accounting Standards Board Concepts Statement No. 1, Objectives of Financial Reporting.