SBA Documentation Required from 8(a) Contractors

In June, the SBA notified 8(a) contractors that it was going to require documentation to substantiate their eligibility to participate in the program. That requirement has now been issued. Per Berenzweig Leonard, the notice is as follows:

The document requests focus on various financial records, subcontracting and vendor agreements, and employment records over the last three fiscal years. SBA established a rapid turnaround for the documentation, setting a due date of January 5, 2026, and stating that any contractors that fail to meet the filing deadline "may lose their eligibility to participate in the 8(a) Program and could face further investigative or remedial actions."

Below are steps that 8(a) participants can take to respond effectively to SBA's data and document requests:

1. Verify that you received the audit email.

• All current participants in the 8(a) program are likely impacted by the document request and should begin taking steps to respond.

• Recent 8(a) participants, including recent graduates and early terminations, are also likely subject to the audit.

• If you did not receive the email, check your email filters. If you are a current 8(a) participant and did not receive the email, reach out to SBA directly to confirm that you are subject to the audit.

2. Compile the required documentation in file types designated by SBA.

3. Upload the required documentation to SBA's online portal by the January 5, 2026, deadline.

• There is currently no indication that contractors will be permitted to request an extension to produce their documentation, so businesses should make every effort to meet the January 5th deadline to avoid any interruption to their 8(a) program eligibility.