Grant compliance is often thought of as financial accountability — making sure grantees spend money for approved purposes and report on it. But compliance in grants management spans the entire grant lifecycle — from how applications are received to how outcomes are reported — and involves the funder's own processes as much as grantee accountability.
This checklist covers compliance requirements at each stage of the grant lifecycle.
Published grant guidelines. Before applications open, grant guidelines must be publicly available — for transparency, and in the case of government grants, as a regulatory requirement. Guidelines should specify eligibility, assessment criteria, and process.
Programme policy approval. The grants policy should be formally approved by the board or governing body before each round. Administering a grant programme without current policy approval creates a governance gap.
Assessor COI declarations. Before any assessment activity begins, all assessors — internal staff and external panellists — should complete COI declarations. Declarations should be documented and retained.
Delegation confirmation. Confirm that the decision-making authority for this round — who can approve what grant sizes — is documented and current. Delegations set years ago may no longer accurately reflect the organisation's structure or risk appetite.
Eligibility verification. Before applications enter assessment, confirm each applicant meets the stated eligibility criteria — correct entity type, correct geographic location, no conflict with excluded categories (for gaming trusts, no for-profit applicants; for government programmes, no politically affiliated organisations).
Charitable status verification. For grantmakers distributing to charities, verify that each applicant is a currently registered charity (NZ Charities Register or ACNC). Charities can be deregistered; verification at the time of each round, not just at initial registration, is important.
Application completeness. Before applications go to assessment, check that each submission is complete — required fields completed, required documents uploaded. Incomplete applications create assessment difficulties and may need to be returned to applicants.
Anti-money laundering checks. For large grants, some funders apply AML-style checks on grantee organisations — particularly for new grantees. This is a proportionate risk management step for significant grants to unfamiliar organisations.
COI management during assessment. Track declared conflicts and ensure conflicted assessors are excluded from the relevant applications. Document the management of each declared conflict.
Assessment documentation. Ensure each application has complete assessment documentation — scores recorded, assessor comments saved, any clarification responses filed. Assessment documentation must be complete before the decision is made.
Panel quorum and delegation compliance. Confirm the panel or decision-maker has the required quorum and delegation authority to make binding decisions for grants of the proposed sizes.
Exception processes. Any application assessed outside the standard process (emergency grants, ministerial discretion, special categories) should be documented with the basis for the exception.
Formal decision record. Every grant decision — approved or declined — must be formally recorded with: the decision, the decision-maker identity and role, the date, and the basis for the decision. Verbal decisions confirmed in writing are acceptable; undocumented verbal decisions are not.
Notifications. Notify all applicants — approved and declined — within the promised timeframe. Delayed notifications without explanation are both poor practice and a breach of stated process.
Grant agreement execution. Every approved grant should have a signed grant agreement. Grants paid without executed agreements have no documented conditions — creating accountability and recovery risks. Retain executed agreements for the full accountability period.
Declined application feedback. Where the programme committed to providing feedback, ensure feedback is provided to declined applicants.
Payment authorisation. Payments must be authorised by someone with appropriate financial delegation. Unauthorised payments — even small ones — are compliance failures.
Bank account verification. Before first payment to any grantee, verify the bank account is registered to the grantee organisation. Payments to unverified accounts are a fraud risk.
Payment against conditions. If payment is conditional (e.g., second tranche released only after milestone completion), confirm conditions are met before releasing payment.
Payment recording. Record every payment in the grants management system — amount, date, authorising officer, bank account. Payment records are part of the accountability audit trail.
Report due date monitoring. Track all grantee reporting due dates. Send automated reminders before due dates; follow up overdue reports promptly.
Report review and acceptance. Formally review and accept (or return for revision) each grantee report. A report submitted but never reviewed is not an accountability success.
Unexpended funds. At acquittal, identify grants where funds were not fully expended. Pursue return of unexpended funds per grant conditions.
Outcome data recording. Record outcome data from grantee reports in the grants management system — this data is needed for programme evaluation and annual reporting.
Tahua supports end-to-end grant compliance with workflow controls, automated reminders, audit trail documentation, and COI management built into every stage of the grant lifecycle.