Municipal FinancePolicy DeadlineJul 13, 2026, 4:23 AM· 5 min read· #2 of 2 in community

US Cities Rush to Meet December Deadline to Expend Billions in ARPA Funds, Prioritizing Government Operations

With the December 2026 deadline approaching, local governments across the U.S. are finalizing the expenditure of their American Rescue Plan Act allocations, focusing heavily on modernizing civic technology and securing long-term infrastructure.

By Factlen Editorial Team

Municipal Leaders 40%Civic Technologists 35%Fiscal Watchdogs 25%
Municipal Leaders
Focused on maximizing the remaining federal funds to secure long-term operational efficiencies and avoid impending budget cliffs.
Civic Technologists
View the final ARPA tranches as a rare catalyst for overdue digital transformation and legacy IT modernization.
Fiscal Watchdogs
Emphasize strict compliance, proper documentation, and the risk of federal clawbacks as the expenditure deadline forces rapid spending.

What's not represented

  • · Local taxpayers who may face increased property taxes if cities fail to manage the post-ARPA fiscal cliff.
  • · Nonprofit subrecipients struggling to complete their community projects before the strict federal deadline.

Why this matters

The $350 billion injection from the American Rescue Plan Act represents a once-in-a-generation modernization opportunity for local governments. How cities spend their final allocations by December will determine whether they face budget cliffs in 2027 or successfully transition to more efficient, technology-driven public services.

Key points

  • Local governments have until December 31, 2026, to fully expend their ARPA State and Local Fiscal Recovery Funds.
  • Large cities and counties successfully obligated 100% of their funds by the 2024 deadline and have already spent roughly 72%.
  • Final expenditures are heavily focused on modernizing legacy IT systems, cloud migration, and physical infrastructure.
  • Municipal leaders are using these operational upgrades to prepare for tighter budgets once the federal funds expire.
  • Strict federal rules mean unspent funds must be returned, forcing cities to closely monitor contractor timelines.
$350B
Total SLFRF allocation
72%
Funds spent by large cities
Dec 31, 2026
Final expenditure deadline
69%
Mayors expecting budget impacts

As the clock ticks toward December 31, 2026, local governments across the United States are entering the final, critical phase of the American Rescue Plan Act (ARPA). The State and Local Fiscal Recovery Funds (SLFRF) program, which injected $350 billion into state, territorial, local, and tribal governments in 2021, requires that every allocated dollar be fully expended by the end of the year. For city halls and county administrative buildings, this means transitioning from planning and obligating funds to ensuring that goods are delivered, services are completed, and final payments are cleared.

The scramble to legally commit the funds—known as the obligation deadline—safely passed in December 2024. According to the National League of Cities, Tier 1 cities and counties successfully obligated 100 percent of their allocations, a massive administrative victory that protected large municipalities from federal clawbacks. Now, the focus has shifted entirely to execution. Data from the Local Government ARPA Investment Tracker indicates that roughly 72 percent of the funds have already been spent, leaving a substantial but manageable final tranche to be deployed over the next six months.

However, municipal finance officers warn that the expenditure phase is often the most complex. To meet the U.S. Department of the Treasury's strict definition of an expenditure, local governments cannot simply hold the money in a dedicated account; the funds must be legally owed and paid out to contractors, vendors, or service providers. If a supply chain delay or a contractor dispute pushes a project's completion date into 2027, the associated ARPA funding could be forfeited, placing the financial burden squarely back on local taxpayers.[1][2]

The timeline of the $350 billion State and Local Fiscal Recovery Funds program.
The timeline of the $350 billion State and Local Fiscal Recovery Funds program.

To mitigate these risks and maximize the impact of the remaining funds, cities are heavily prioritizing internal government operations and civic technology. While the earliest waves of ARPA funding were directed toward emergency public health responses, hazard pay, and immediate revenue replacement, the final wave is being treated as a generational capital investment. Local leaders recognize that once the federal lifeline expires, they will need highly efficient operational systems to manage tighter budgets.

A primary target for these final expenditures is the modernization of aging legacy IT systems. State and local governments are utilizing ARPA dollars to migrate data to the cloud, digitize public records, and overhaul property tax collection software. Civic technology advocates describe the funding as a 'once in a lifetime opportunity' to address deferred digital maintenance that standard municipal budgets rarely accommodate. By upgrading these systems now, cities hope to permanently reduce their annual software maintenance costs and improve the delivery of digital services to residents.

A primary target for these final expenditures is the modernization of aging legacy IT systems.

Beyond technology, physical infrastructure and public works remain a top priority for the remaining funds. Cities are finalizing contracts for water line replacements, stormwater drainage upgrades, and broadband expansion projects. Because the Treasury's Final Rule offers limited flexibility to reclassify funds after the 2024 obligation deadline, municipalities are meticulously monitoring these large-scale construction projects. If a project comes in under budget, the surplus funds cannot easily be shifted to a new initiative, requiring cities to carefully manage change orders and existing contracts to ensure every dollar is utilized.[2]

Cities are heavily prioritizing civic technology and legacy IT modernization with their remaining federal allocations.
Cities are heavily prioritizing civic technology and legacy IT modernization with their remaining federal allocations.

The looming deadline is also forcing local governments to confront a significant fiscal challenge: the post-ARPA budget cliff. According to the 2025 State of the Cities report, 69 percent of surveyed mayors indicated that the end of ARPA funding will negatively impact their municipal budgets. Over the past five years, many jurisdictions used federal relief funds to cover recurring operating costs, effectively delaying difficult decisions about property tax rates and service cuts.

As the December deadline approaches, finance directors are actively working to transition temporary ARPA-funded programs into their general funds. In some cities, specialized project management teams hired specifically to oversee ARPA infrastructure deployments have proven so effective that their salaries are being permanently absorbed by the city to maintain faster project delivery speeds. Other municipalities are relying on the newly upgraded tax collection software purchased with ARPA funds to close the upcoming budget gap, hoping that better collection rates will organically boost revenue without requiring a tax hike.

The administrative burden of the final ARPA phase extends beyond city hall. Local governments that distributed funds to community nonprofits and local businesses—acting as subrecipients—are responsible for ensuring those partners also meet the December 2026 expenditure deadline. Municipal auditors are currently conducting extensive outreach to these organizations, verifying that community-led projects are on track and that all expenditures are properly documented to withstand future federal audits.[1][2]

A majority of municipal leaders anticipate budget tightening once federal relief funds expire.
A majority of municipal leaders anticipate budget tightening once federal relief funds expire.

Reporting requirements will outlast the spending deadline itself. Even after a municipality has spent its final ARPA dollar, it must continue submitting detailed annual or quarterly reports to the Treasury until the federal government officially closes out the award, a process expected to stretch into 2027. This prolonged compliance tail requires cities to retain dedicated grant management staff well after the actual project work has concluded.[2]

Despite the bureaucratic hurdles and the pressure of the ticking clock, the successful deployment of ARPA funds represents a historic achievement in local governance. The $350 billion program tested the capacity of municipal governments to absorb, allocate, and execute massive federal investments under intense public scrutiny. By prioritizing long-term operational upgrades in these final months, cities are ensuring that the legacy of the American Rescue Plan extends far beyond pandemic recovery.[1]

Ultimately, the communities that successfully navigate this final expenditure deadline will emerge with more resilient infrastructure, modernized digital services, and more efficient civic operations. As local leaders sign their final ARPA-funded contracts this year, they are closing a unique chapter in American municipal finance—one that has fundamentally reshaped the baseline capabilities of local government for the next decade.

How we got here

  1. March 2021

    The American Rescue Plan Act is signed into law, allocating $350 billion to state and local governments.

  2. January 2022

    The U.S. Treasury issues the Final Rule, establishing the eligible uses and strict deadlines for the SLFRF program.

  3. December 2024

    The obligation deadline passes, requiring all municipalities to have legally committed their funds to specific contracts or projects.

  4. July 2026

    Cities enter the final six-month sprint to ensure all obligated projects are completed and paid out.

  5. December 2026

    The final expenditure deadline; all ARPA funds must be fully spent, with unspent dollars subject to federal clawbacks.

Viewpoints in depth

Municipal Leaders' View

City and county officials are prioritizing permanent operational upgrades to cushion the blow of the upcoming fiscal cliff.

For local mayors and finance directors, the end of ARPA represents a looming financial threat. With 69 percent of surveyed municipal leaders anticipating negative budget impacts once the federal funds dry up, the strategy has shifted from temporary relief to permanent efficiency. By investing the final dollars into automated systems, streamlined project delivery teams, and modernized public works, municipal leaders hope to organically reduce their baseline operating costs before the 2027 fiscal year begins.

Civic Technologists' View

Technology advocates see the deadline as the final push to drag legacy government systems into the modern cloud era.

Industry experts and civic technologists argue that standard municipal budgets rarely have the capital required to replace massive, decades-old legacy IT systems. They view the ARPA SLFRF program as a once-in-a-generation windfall that allows cities to bypass the usual protracted procurement fights. By directing the remaining funds toward cloud migration, cybersecurity, and digital service portals, technologists believe cities can fundamentally alter how residents interact with local government, saving millions in future maintenance costs.

Fiscal Watchdogs' View

Compliance experts warn that the rush to spend could lead to administrative errors, unallowable costs, and federal clawbacks.

Legal and financial compliance experts are sounding the alarm over the strictness of the December 2026 expenditure deadline. Because the U.S. Treasury requires funds to be fully paid out—not just contracted—watchdogs warn that supply chain delays or contractor disputes could leave cities holding the bag for millions of dollars in unfinished projects. They are urging local governments to aggressively monitor their subrecipients and maintain meticulous audit trails, noting that federal reporting requirements will continue long after the money is spent.

What we don't know

  • How many local governments will ultimately be forced to return unspent funds due to late-stage supply chain or contractor delays.
  • The exact severity of the 'fiscal cliff' cities will face in 2027 once the federal funding is completely exhausted.
  • Whether the U.S. Treasury will offer any last-minute administrative leniency for projects delayed by factors outside a municipality's control.

Key terms

ARPA
The American Rescue Plan Act, a 2021 federal stimulus package that provided economic relief during the COVID-19 pandemic.
SLFRF
State and Local Fiscal Recovery Funds, the specific $350 billion program within ARPA directed to state, local, territorial, and tribal governments.
Obligation
A legal commitment to spend funds, such as signing a contract or issuing a purchase order, which had to be completed by December 2024.
Expenditure
The actual payment of funds for goods delivered or services rendered, which must be completed by December 2026.
Clawback
The process by which the federal government reclaims unspent or improperly allocated grant funds from a local jurisdiction.
Subrecipient
A non-federal entity, such as a local nonprofit or business, that receives a portion of a government's grant funding to carry out a program.

Frequently asked

What is the December 2026 ARPA deadline?

December 31, 2026, is the final expenditure deadline for the ARPA State and Local Fiscal Recovery Funds. By this date, all allocated money must be fully paid out for completed services or delivered goods.

What happens if a city misses the deadline?

Any funds that are not fully expended by the deadline must be returned to the U.S. Treasury, and the local government will be responsible for covering the remaining costs of any unfinished projects.

How are cities spending the remaining funds?

While early funds went to emergency pandemic relief, cities are using their final allocations to modernize legacy IT systems, upgrade physical infrastructure, and improve internal government operations.

Did cities meet the previous obligation deadline?

Yes, data shows that Tier 1 cities and counties successfully obligated 100 percent of their funds by the December 2024 deadline, legally committing the money to specific projects.

Sources

Source coverage

2 outlets

3 viewpoints surfaced

Municipal Leaders 40%Civic Technologists 35%Fiscal Watchdogs 25%
  1. [1]Route FiftyFiscal Watchdogs

    Local officials warn 2026 ARPA spending deadline is uncomfortably close

    Read on Route Fifty
  2. [2]UNC School of GovernmentFiscal Watchdogs

    The Countdown to the ARP/CSLFRF Expenditure Deadline

    Read on UNC School of Government
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