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Compliance Alert: Mandatory Action Required as SBA Initiates 8(a) Program Audit

The SBA has issued a mandatory data call to all 8(a) Business Development Program participants, requiring submission of specific data and supporting documents by January 5, 2026, through the Small Business Administration’s (SBA’s) secure portal. Failure to comply may result in loss of program eligibility and could lead to additional enforcement actions.

Recent investigations have renewed concerns about misconduct within the SBA’s 8(a) program, which was created to support socially and economically disadvantaged businesses. Reports suggest that, over time, the program has become vulnerable to abuse, raising questions about oversight and the use of taxpayer funds.

SBA is requiring the below documentation:

  1. General ledger for the last three full fiscal years (CSV files only)
  2. Trial balance as of the last day for each of the last three fiscal year-ends (CSV files only)
  3. IRS Form 4506 covering the last three full fiscal years (PDF files only)
  4. Bank statements as of the last day for each of the last three fiscal year-ends (PDF files only)
  5. Bank reconciliations as of the last day for each of the last three fiscal year-ends (PDF files only)
  6. Payroll register and reconciliation (including any distributions to any owner), monthly for the last three full fiscal years (PDF files only)
  7. List of all employees, broken out by contracts those employees are servicing, for the last three full fiscal years (PDF files only)
  8. List of all vendors (as well as all joint ventures) for the last three full fiscal years (PDF files only)
  9. Copy of all 8(a) contracts on which the firm is currently working for the last three full fiscal years (PDF files only)
  10. Subcontracting agreements related to the contracts in item nine (for the last three full fiscal years) (PDF files only)
  11. Financial statements which include, at a minimum, the year-end balance sheet, YTD profit-and-loss (P&L), cash flow statement, and the statement of equity for each of the last three fiscal years (CSV files only)
  12. Financial statement reconciliation to the year-end trial balance for the last three fiscal years (CSV files only)
  13. For each of the last three full fiscal years, a sub-ledger schedule tying to the year-end trial balance accounts for: all accounts receivable accounts, all accounts payable accounts and all P&L accounts (CSV files only)

Note: Data requested in a monthly increment would not be duplicative of the same data already submitted in an annualized form and would have to be submitted in the monthly increment.

Guiding Your Business Forward 

Navigating these compliance requirements can be complex. Cherry Bekaert’s experienced advisors are ready to guide your business through the SBA’s data request process. We can help you review your documentation, provide timely submissions and address any compliance concerns — so you can focus on your business with confidence.

If you need support or have questions about the SBA’s 8(a) program review, Cherry Bekaert is here to help you move forward.

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Ed Jameson

Government Contracting Leader

Partner, Cherry Bekaert Advisory LLC

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Traci Shepps

Government Contractor Consulting Services

Partner, Cherry Bekaert Advisory LLC

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Lynnette Leidwinger

Government Contractor Consulting Services

Director, Cherry Bekaert Advisory LLC

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Connect With Us

Ed Jameson headshot

Ed Jameson

Government Contracting Leader

Partner, Cherry Bekaert Advisory LLC

Traci Shepps headshot

Traci Shepps

Government Contractor Consulting Services

Partner, Cherry Bekaert Advisory LLC

Lynnette Leidwinger headshot

Lynnette Leidwinger

Government Contractor Consulting Services

Director, Cherry Bekaert Advisory LLC