Are EIDL loans subject to single audit?
Yes for COVID-19 EIDL loans: SBA states that a nonprofit borrower that expended enough loan funds, with other federal awards, in a single year is subject to the Single Audit Act, and that the requirement applies in the year the funds are spent. SBA states that EIDL Advances are not subject to the Act (SBA).
Last verified: 2026-09-20 · Every figure links its source.
Are EIDL loans subject to single audit?
SBA's COVID-era programs page is explicit for nonprofit borrowers, and it adds the timing rule that matters: “because there are no continuing compliance requirements, these audit requirements only apply in the year that the loan funds are spent” (SBA). Note that the dollar figure on that page, $750,000, is the pre-2024 threshold; the current text of 2 CFR 200.501(a) sets $1,000,000.
| Program | Single audit treatment per SBA | Source |
|---|---|---|
| COVID-19 EIDL loan (nonprofit borrower) | Subject to the Single Audit Act in the year the loan funds are spent, counting other federal awards | SBA |
| EIDL Advance | Not subject to the Single Audit Act | SBA |
| Shuttered Venue Operators Grant | Has its own program section in the Compliance Supplement (Assistance Listing 59.075) | Compliance Supplement part 4 |
| PPP | No statement on SBA's page and no program section in the Supplement | SBA |
Source: SBA, COVID-era programs · Compliance Supplement 2025, part 4 (SBA) · 2 CFR 200.501 · Last verified: 2026-09-20
Does borrowing federal money trigger a single audit?
It can, because loans are one of the things the rules count. The value of federal awards expended for a loan program is the new loans made during the audit period plus any prior balances that still carry compliance requirements, together with interest subsidies or administrative cost allowances received (2 CFR 200.502(b)). Where a loan carries no continuing compliance requirement beyond repayment, prior-year balances drop out of the calculation.
Two consequences people miss: a loan can put you over the threshold in the year you draw it, and a loan program with continuing requirements keeps counting in later years even though no new money arrived.
Source: 2 CFR 200.502 · Last verified: 2026-09-20
Does a loan refinance with federal dollars trigger a single audit?
Ask the same question the regulation asks: in this fiscal year, what federal awards did you expend? A refinance that replaces private debt with a federal loan means new federal loan value in that year, and the valuation rules in 200.502(b) apply to it. A refinance between two private lenders is not a federal award at all. If the lender cannot tell you the Assistance Listing number, that is the first thing to resolve — you cannot put a program on the schedule without one.
Source: 2 CFR 200.502 · 2 CFR 200.510 · Last verified: 2026-09-20
What about Provider Relief Fund payments?
Provider Relief Fund money is administered by HRSA, which publishes its own reporting and auditing requirements for recipients (HRSA Provider Relief). Health care nonprofits that received it should read HRSA's audit page for the year in question alongside the Compliance Supplement section for the program, because the reporting periods do not always line up with the fiscal year.
Source: HRSA Provider Relief Fund · OMB Compliance Supplement · Last verified: 2026-09-20
Questions and answers
Are EIDL loans subject to single audit?
SBA states that a nonprofit COVID-19 EIDL borrower that expended enough loan funds, together with other federal awards, in a single year is subject to the Single Audit Act, in the year the funds are spent. EIDL Advances are not subject to the Act.
Does borrowing federal money trigger single audit?
It can. Loan programs are valued as new loans made in the period plus prior balances that still carry compliance requirements, so a loan can take an organization over the threshold.
Does loan refinance with federal dollars trigger single audit?
If the refinance brings in a new federal loan, that value counts in the year it is made under the valuation rules in 2 CFR 200.502(b). A refinance between private lenders is not a federal award.
Count your federal spending first: check the threshold.
This is public-record information, not accounting or legal advice.