Home / Resources / Do we need timesheets?
Updated August 2026
Short answer: not in the way most people think. Here's what the rules actually ask for — and why the distinction saves small organizations a lot of pointless work.
Federal rules require records that reasonably reflect how staff actually spent their time, supported by internal controls and certified by someone who knows. They do not mandate timesheets. A documented, consistently applied method that produces defensible records satisfies the rule.
Before the Uniform Guidance, older circulars were more prescriptive, and a generation of grant managers learned "you need timesheets." The rules were rewritten to be outcome-based, but the folklore stuck — so small organizations still build elaborate timekeeping systems they were never asked for, or panic when they discover they don't have one.
Under 2 CFR 200.430, the records must reflect the total activity for which the employee is compensated, cover federal and non-federal work alike, sit inside your official records, and be supported by an internal control system giving reasonable assurance the charges are accurate.
Nowhere does that say "timesheet." It describes a standard your records must meet.
There is a real exception, and it catches people who read only the headline. §200.430(g)(3) says that for nonexempt employees — hourly staff entitled to overtime — Department of Labor rules implementing the Fair Labor Standards Act (29 CFR part 516) mean your charges must also be supported by records showing the total number of hours worked each day.
So for hourly staff you do need a daily hours record, but not because of the grant rules — because of wage-and-hour law, which applies whether or not a federal grant is involved. The grant rules add the effort-distribution question on top of it. For salaried exempt staff, no daily hours record is required by either.
It means you can pick a method that fits how your organization actually works, as long as you can describe it, apply it consistently, and defend the output. For a five-person organization that might be a monthly activity record per person, reviewed and certified by a supervisor. For a larger one it might be detailed daily entry.
It does not mean documentation is optional. The obligation is real and payroll allocation is a recurring audit finding. What's optional is the format.
Your specific award may add requirements. Individual federal agencies issue their own guidance, and a pass-through entity — a state agency or a larger nonprofit — can impose stricter terms in your subaward agreement than the federal minimum.
So the accurate statement is: the Uniform Guidance does not prescribe timesheets as your effort documentation, but wage-and-hour law requires daily hours for nonexempt staff, and your grant agreement may add more. Read the agreement, and ask your grant officer if it's unclear.
This is general information, not legal or accounting advice. Federal grant rules change and are applied differently by different agencies and auditors. Check with your auditor, your grant officer, or an attorney before relying on any of it.
The Ember tool for thisEmber Staff logs staff time, splits it across grants and programs by actual effort, routes it for supervisor certification, and produces an audit-ready time-and-effort report — with unlimited users on every plan.
Not as a prescribed form. 2 CFR 200.430 requires records that reasonably reflect actual work, supported by internal controls. Two caveats: §200.430(g)(3) requires daily hours records for nonexempt (hourly) employees under the Fair Labor Standards Act, and your individual award or pass-through agreement may be stricter.
Any documented, consistently applied method producing records that cover total activity, are contemporaneous, certified by someone with firsthand knowledge, and reconcile to payroll.
It can be, for many small organizations, if it covers total activity and is certified. The rule sets a standard, not a frequency — but check your award terms.
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Sources: 2 CFR Part 200 (eCFR) — §200.430. Verified August 2026.