JD Supra reports that U.S. Small Business Administration (SBA) has centralized the authority for approving or denying continued participation in the 8(a) Business Development program following annual reviews. The change, effective February 20, 2026, shifts final decision-making authority from SBA district offices and Business Opportunity Specialists to the Associate Administrator for Government Contracting and Business Development (AA/GCBD) or a designated official.
The policy was announced in SBA Policy Notice No. 6000-876995 and is intended to strengthen oversight of the 8(a) program. Under the new directive, SBA personnel may still review annual submissions for completeness and compliance, but they are no longer permitted to make final determinations regarding whether a company remains eligible for the program.
The move follows the SBA’s February 2026 announcement that it was proposing the termination or suspension of 154 Washington, D.C.-based 8(a) firms that the agency alleged had remained in the program despite failing to meet eligibility requirements during prior annual reviews.
The centralization of authority is expected to bring greater scrutiny to annual review submissions, particularly for entity-owned 8(a) participants such as subsidiaries of Alaska Native Corporations, Tribes, and Native Hawaiian Organizations.
A key area of focus will be compliance with business activity targets (BAT), which require companies in the later stages of the 8(a) program to generate increasing levels of non-8(a) revenue. Beginning in the fifth year of participation, firms must meet progressively higher thresholds of non-program revenue through year nine.
Failure to meet these targets can result in corrective action requirements, restrictions on receiving sole-source 8(a) contracts, or other compliance measures if the SBA determines that the company did not make good-faith efforts to diversify its revenue sources.
Legal analysts say the shift to centralized review could also increase the risk of adverse outcomes for some firms, as eligibility determinations will now be made at SBA headquarters rather than by local officials familiar with a participant’s business environment.
The new review structure may also lead to longer processing times for annual reviews, as all final eligibility determinations must now pass through the Associate Administrator’s office or an authorized designee.
For 8(a) participants, the change underscores the importance of submitting well-documented annual review materials and demonstrating clear compliance with program requirements as the SBA implements its revised oversight framework.
