CGA Law News & Blog

The Clock is Ticking – Obligate ARPA Funds Before the Deadline

access_time Posted on: February 15th, 2024

The American Rescue Plan Act (ARPA) has provided many local governments with a financial boost to tackle the challenges the pandemic presented. However, with the deadline to obligate these funds less than a year away, municipalities must be mindful of the time limitations associated with the funds to ensure optimal utilization for their community’s benefit.

Local governments have until December 31, 2024, to obligate all received ARPA funds. This means the governing bodies of municipalities must allocate the funds to specific projects, programs, or initiatives before this date to avoid loss of funds. Under the Final Rule, failure to meet this deadline will result in the forfeiture of unallocated funds.

While obligating the ARPA funds is the first essential step, ensuring that the obligated funds are spent within the designated timeframe is equally important. The deadline for spending the obligated ARPA funds is December 31, 2026. Municipalities must plan and execute their projects accordingly to meet these deadlines and derive maximum benefit from the funds provided.

Municipalities should take active steps in the coming months to discuss and take official action to obligate all remaining ARPA funds on projects, programs, or initiatives that will reasonably result in the expenditure of all funds by the December 31, 2026. If you have questions about the obligation and expenditure of ARPA funds or how the American Rescue Plan Act impacts the municipality you serve, contact your CGA Attorney or Attorney Beth Kern.

Reminder – Annual ARPA Funds Reporting Deadline April 30, 2024

The next annual Project and Expenditure report for the American Rescue Plan Act (ARPA) funding is due on or before April 30, 2024.  This Project and Expenditure report will cover the time period of April 1, 2023 – March 31, 2024. ARPA funds that have been obligated and spent during this time period, as well as updates to total obligations and spending will need to be reported on the annual Project and Expenditure report.

The annual Project and Expenditure report must be filed by every local government ARPA recipient whether or not it obligated or spent any of the funds during the corresponding reporting period.         

Since local government recipients have until December 31, 2024 to obligate all received ARPA funds and until December 31, 2026 to spend all obligated funds, the annual reporting requirements will continue until April of 2027.       

If your municipality is experiencing difficulty with the reporting or would otherwise like help with the reporting, CGA can help.  We can provide assistance in person or via a video meeting with completing the reporting or answering questions your municipality has about the ARPA reporting. 

Beth Kern

Beth J. Kern


Beth J. Kern provides legal services to Municipal, Business, Employment, Land Use, and Real Estate Law clients. Beth brings to her clients and practice a diverse background with over twelve years of professional experience in business and human resources management. Before joining CGA, Beth worked for Flagger Force®, a rapidly growing multi-state traffic control company, as a Human Resources professional while attending Widener Commonwealth Law School in the evening. Beth uses her business acumen and experience in human resources management to gain insight into partnering with leaders and teams to develop organization strategies. She knows that the most successful solutions are developed in partnership with the people within an organization and she loves helping clients achieve their goals.

Read Beth’s Bio Page in full HERE.