How funding volatility, digital risk and AI are reshaping governance
Executive summary
Not-for-profits are operating in a period of accelerating policy and regulatory change where funding decisions, regulatory scrutiny and technology risk increasingly intersect. For many organizations, uncertainty is no longer confined to compliance checklists or annual audits. It is shaping cash flow, governance decisions, public trust and the ability to deliver on mission commitments. Insights from NFP leaders across policy, governance and compliance suggest that resilience in this environment depends less on predicting outcomes and more on preparedness.
Not-for-profit (NFP) organizations have always operated in complex environments. Digital fundraising and data privacy obligations now span dozens of jurisdictions at once. What has changed is the pace at which policy decisions, regulatory expectations and public scrutiny collide. Funding rules can shift mid-cycle. Oversight intensity can rise without warning.
These pressures are no longer confined to compliance or legal teams. They influence how NFP leaders plan and deliver programs, manage cash flow and communicate with stakeholders. Uncertainty today is not just about what will happen next, but whether decisions made in the past will be revisited, paused or reversed.
Conversations with NFP policy, governance and compliance leaders point to a clear pattern. Organizations that treat regulatory intelligence and governance as core operating disciplines are better positioned to absorb volatility. Those that rely on reactive responses are finding the margin for error shrinking.
Funding uncertainty is the most immediate risk
When NFP leaders discuss regulatory risk, tax rules or reporting requirements often come to mind first. In practice, however, funding volatility is where uncertainty is felt most acutely.
“The largest risk for this space, in my mind, continues to be funding,” said Charles Cooper, founder and managing partner of the Brumidi Group. “Processes in D.C. are somewhat broken, which drives uncertainty in timing. Partisanship drives uncertainty around what ultimately gets funded.”
Beyond future appropriations, organizations must also consider the stability of existing funding. Cooper noted that uncertainty now extends to whether federal programs will be reauthorized, reduced or halted midstream. For NFP organizations that rely directly or indirectly on federal funding, that ambiguity complicates everything from hiring decisions to long-term commitments.
In this environment, consistent engagement matters. “If you’re not engaging on a regular basis, your risk profile goes up significantly,” Cooper said. Relationships built before a crisis are often the ones that help organizations navigate uncertainty when it arrives.
Bipartisanship and message discipline reduce exposure
One common misstep, Cooper said, is NFP leadership aligning too closely with one side of the aisle. “If you’re not operating on a bipartisan basis, you’re taking two steps backwards,” he said. Oversight authority and funding decisions rarely rest with a single group. Flexibility depends on credibility across audiences.
Message discipline is equally important. “This is a messaging town,” Cooper said. “Message often leads policy.” Organizations that improvise messaging during a crisis risk inconsistency and confusion. Leaders emphasize the value of clear, pre-defined narratives that speak to mission impact and stewardship, not politics.
Experienced partners also play an important role. Navigating policy risk without a deep understanding of how Washington operates often leads to miscalculation. The system is driven by policy, politics and shifting priorities, Cooper said, not business norms.
Compliance blind spots are often structural
From a governance and audit perspective, many compliance failures stem from structure rather than intent.
Dennis Morrone, Head of Not-for-Profit & Higher Education Industry, noted that NFP organizations with significant federal funding often demonstrate strong discipline around grant compliance. “There is genuinely a fear of non-compliance,” he said. “From what we generally see, entities are spending those monies in a manner that conforms with the terms of the agreement.”
Where blind spots emerge are in areas that feel indirect or fragmented. Digital fundraising is a prime example. Campaigns that cross state lines can trigger registration and disclosure requirements that teams may not anticipate.
Danielle Cook, Associate Director, Public Policy and Government Affairs, pointed to a common misconception. “There’s a belief that if I send out a solicitation to a national audience, or just have a passive website, I’m fine,” she said. “But with so many different state laws, you can trigger registration and disclosure requirements that organizations may not be aware of.”
Third-party platforms do not remove that responsibility, as they typically have no responsibility for an NFP’s compliance,” Cook said.
Boards are asking more questions, but rigor varies
Board oversight is intensifying, driven by high-profile fraud cases and rising reputational risk. NFP directors are asking more questions about controls, audits and technology use.
What concerns Morrone is the gap between questions and analysis. “More often than not, management teams give boards the comfort they’re requesting,” he said. “But I’m not sure they’ve really done the type of rigorous analysis and review that’s necessarily warranted.”
That gap can persist until an external event forces deeper scrutiny. Morrone said this moment creates an opening. Organizations can use heightened board attention to revisit governance structures, policies and risk oversight with an eye on today’s realities, not those of prior cycles.
AI is already embedded, governance often is not
Technology is shaping compliance and communications whether leaders plan for it or not. Many NFPs are already using AI to draft content, analyze data or streamline workflows.
Used thoughtfully, AI can reduce risk. Used casually, it can introduce new exposure. In that regard, Cook cautioned that people are becoming more savvy about when messages appear AI-generated. “That creates a huge disconnect from your audience.” She said AI should support, not replace, an organization’s voice.
Morrone added that boards are increasingly focused on how technology might help surface anomalies or misuse of funds. The challenge is that many NFPs are still in the formative stages of understanding what these technology tools can and cannot do.
How we can help you
SERVICES
SERVICES
A pragmatic path forward for mid-market organizations
Resilience does not require sweeping transformation. For NFP leaders who consistently emphasize practicality, the first step is clarity. Ask:
- Who owns regulatory monitoring?
- Who is accountable when compliance cuts across fundraising, technology and finance?
From there, a targeted use of automation can deliver early value by monitoring deadlines, scanning for policy changes or flagging financial anomalies, which reduces friction without overburdening teams.
Over time, governance can mature. Morrone said consideration of automation may also be an opportunity for an NFP to conduct a governance review, examining whether policies, processes and oversight have kept pace with regulatory and technological change.
Conclusion
Regulatory acceleration is no longer theoretical for NFPs. It is shaping funding stability, governance expectations and public trust in real time.
Organizations that continue to view compliance as overhead will face rising exposure. Those that elevate regulatory intelligence, strengthen board oversight and use technology with discipline are better positioned to sustain their missions.
Uncertainty will remain. Preparedness does not eliminate risk, but it narrows surprises. In today’s regulatory environment, NFP resilience is built through clarity, engagement and governance long before a crisis appears.
Contacts:
Head of Not-for-Profit & Higher Education Industry
Partner, Audit Services, Grant Thornton LLP
Content disclaimer
This Grant Thornton Advisors LLC content provides information and comments on current issues and developments. It is not a comprehensive analysis of the subject matter covered. It is not, and should not be construed as, accounting, legal, tax, or professional advice provided by Grant Thornton Advisors LLC. All relevant facts and circumstances, including the pertinent authoritative literature, need to be considered to arrive at conclusions that comply with matters addressed in this content.
Grant Thornton Advisors LLC and its subsidiary entities are not licensed CPA firms.
For additional information on topics covered in this content, contact a Grant Thornton Advisors LLC professional.
Trending topics
No Results Found. Please search again using different keywords and/or filters.
Share with your network
Share