Key Details: On December 5, 2025, the U.S. Small Business Administration (SBA) issued document requests that require all participants in the 8(a) Business Development Program to submit extensive financial and business documentation by January 5, 2026. This move marks an aggressive compliance review for the program, signaling heightened scrutiny and a commitment to program integrity. For the approximately 4,300 firms currently certified under the 8(a) Program, the message is clear: prepare now or risk losing eligibility.
Why the SBA Is Auditing the 8(a) Program
As noted in our prior release here, the SBA announced an immediate full-scale audit of the 8(a) Program in June 2025. The goal of the audit was to improve oversight of the program and uncover any fraud, bribery, or systemic vulnerabilities.
Required Documentation for 8(a) Government Contractors
The SBA’s data call is extensive and covers three full fiscal years of records. Firms must upload documents to a portal in specific formats (CSV or PDF). Some document categories include:
- General ledger (CSV) for the last three fiscal years.
- Trial balance (CSV) at the end of the last three fiscal years.
- IRS Form 4506 (PDF) for the last three years.
- Bank statements and bank reconciliations (PDF) for all accounts as of the last day for the last three years.
- Monthly payroll registers and payroll reconciliations (PDF) and owner distributions for the last three fiscal years.
- Employee lists for the last three fiscal years, broken down by contract assignments (PDF).
- Vendor and joint venture lists (PDF) for the last three fiscal years.
- Copies of all 8(a) contracts and related subcontracting agreements for the last three fiscal years (PDF).
- Year-end financial statements (including balance sheet, P&L, cash flow, and equity) for the last three fiscal years (CSV).
- Financial statement reconciliations to the trial balances for the last three fiscal years (CSV).
- Sub-ledger schedules for accounts receivable, accounts payable, and all P&L accounts for the last three fiscal years (CSV) that tie to the trial balances.
Documents are due by January 5, 2026. Failure to comply may result in loss of program eligibility or suspension.
How to Prepare for the SBA 8(a) Audit
Time is short, and the SBA has not indicated that extensions will be granted. Contractors should review the list below immediately:
- Verify receipt of the SBA’s document request and audit notice. Check your email and spam folders. Contract the SBA immediately if you are an active participant and have not received an email.
- Organize the documentation by category and format. Ensure all files meet the SBA’s specifications.
- Conduct an internal compliance review and confirm that the documents you are submitting are reconciled.
- Speak with your attorney and review your documents with them.
For more information and expertise, contact Ryan & Wetmore today.
About Rosie Cheng
Senior Finance Consultant
Rosie Cheng is a Senior Finance Consultant at Ryan & Wetmore. She focuses on government contracting services and produces many of the firm’s government contracting newsletters. Rosie earned her Master of Science in Management from Georgetown University and a BBA from William and Mary.
