On December 5, 2025 the U.S. Small Business Administration (SBA) issued data call letters to all 8(a) Business Development Program participants – approximately 4,300 firms. According to the letter, every firm must submit a comprehensive set of financial documents for the last three fiscal years, including bank statements, financial statements, general ledgers, payroll registers, contracting and subcontracting agreements, and employment records. All information was originally required to be uploaded to the MySBACertifications portal by January 5, 2026, however that deadline has now been extended to January 19, 2025. Firms that fail to comply by January 19 may lose their eligibility to participate in the 8(a) Program and could face “further investigative or remedial actions”.
This data call is a follow-up to a June 27, 2025 SBA news release stating that it was launching a “full-scale audit” of its entire 8(a) Business Development Program. SBA and other agencies, including the Treasury Department, have been increasingly vocal about the perception that the program is a vehicle for “rampant abuse and fraud.” The June 27 news release stated that the audit would begin with a focus on high-dollar, limited-competition and sole-source contracts. However, SBA has now expanded its audit to cover the entire program.
SBA is requiring each 8(a) firm to provide the following documents:
- General ledger for the last three full fiscal years (CSV only)
- Trial balance as of each of the last three fiscal year-ends (CSV only)
- IRS Form 4506 for the last three years (PDF only)
- Bank statements for all accounts as of the last day of each fiscal year (PDF only)
- Bank reconciliations as of the last day of each fiscal year (PDF only)
- Monthly payroll registers and reconciliations, including any owner distributions, for the past three years (PDF only)
- A list of all employees broken out by the contracts they serviced during the last three years (PDF only)
- A list of all vendors and any joint ventures used during that period (PDF only)
- Copies of all 8(a) prime contracts performed during the last three years (PDF only)
- All subcontracting agreements related to those contracts (PDF only)
- Year-end financial statements for each year, including balance sheet, year-to-date profit and loss statement, cash flow statement, and statement of equity (CSV only)
- A financial reconciliation of those statements to the year-end trial balance for each year (CSV only)
- A sub-ledger schedule for each fiscal year covering accounts receivable, accounts payable, and all profit and loss accounts (CSV only)
8(a) Program History
The SBA 8(a) Program, named for Section 8(a) of the 1958 Small Business Act, officially began with its statutory authorization in 1978 through amendments to the Act. The Program is a 9-year federal initiative helping small businesses owned by socially and economically disadvantaged individuals grow through counseling, training, and access to government contracts, offering sole-source and set-aside opportunities, mentorship, and technical guidance to build competitiveness in the federal marketplace. Eligibility requires U.S. citizenship, small business status, and ownership by disadvantaged individuals, with strict financial and personal criteria. SBA 8(a) companies are small businesses owned by socially and economically disadvantaged U.S. citizens, including specific entities like Native American tribes, Alaska Native Corporations (ANCs), and Native Hawaiian Organizations (NHOs).
Action for 8(a) Contractors
It remains to be seen what, if anything, will result from SBA’s audit. Outcomes and potential program changes are dependent on findings, and no definitive completion date for the entire audit process has been publicly released. Changes to the current 8(a) program could obviously result in significant financial impacts for many firms. 8(a) firms should ensure that they fully comply with the data call and provide all data requested by SBA. Again, SBA has indicated that failure to meet the deadline could result in loss of 8(a) eligibility or lead to “further investigative or remedial action.”
Need help preparing your SBA submission?
Contact BDO’s Government Contracting team today to ensure your 8(a) compliance and protect your program eligibility.