Does a PPP loan trigger a single audit?
On the federal sources we can open, no: SBA's COVID-era program page sets out a single audit requirement for nonprofit COVID-19 EIDL borrowers and says nothing of the kind for PPP, and the SBA part of the current Compliance Supplement contains no PPP program section. Confirm with your auditor against the Supplement edition that matches your audit period.
Last verified: 2026-09-20 · Every figure links its source.
What the federal sources actually say
Three things are checkable today, and they are worth separating from the advice you will read elsewhere.
| Source | What it says about PPP |
|---|---|
| SBA, COVID-era programs | States a Single Audit Act requirement for nonprofit COVID-19 EIDL borrowers. No equivalent statement appears for PPP. |
| Compliance Supplement 2025, part 4 (SBA) | Contains one SBA program section, Assistance Listing 59.075 (Shuttered Venue Operators Grant). There is no PPP program section for auditors to test against. |
| 2 CFR 200.502(b) | Sets how loans are valued when they are federal awards expended: new loans made in the period plus prior balances that still carry compliance requirements. |
What we could not find on an official page is a sentence that says in so many words “PPP loans are not reported on the schedule of expenditures of federal awards”. Practitioners generally reach that conclusion because a PPP loan was made by a commercial lender with an SBA guarantee under section 7(a), so the federal assistance runs to the lender rather than to the borrower. That is a reading of the structure, not a quotation, and we mark it as such.
Source: SBA, COVID-era programs · Compliance Supplement 2025, part 4 (SBA) · 2 CFR 200.502 · Last verified: 2026-09-20
Why EIDL is treated differently
COVID-19 EIDL was a direct loan from SBA to the borrower. SBA states that a nonprofit COVID-19 EIDL borrower that expended $750,000 or more in loan funds, together with other federal awards, in a single year is subject to the Single Audit Act, and that because there are no continuing compliance requirements the audit requirement applies only in the year the loan funds are spent. SBA also states that EIDL Advances are not subject to the Act (SBA).
One caution on that page: the dollar figure quoted there is $750,000, which was the threshold before the current text of 2 CFR 200.501(a), now $1,000,000. Use the regulation for the threshold and the agency page for the treatment of the program.
Source: SBA, COVID-era programs · 2 CFR 200.501 · Last verified: 2026-09-20
Is PPP loan forgiveness reported on the SEFA?
The schedule reports federal awards expended, program by program, by Assistance Listing number (2 CFR 200.510(b)). If a program is not a federal award to your organization, there is no Assistance Listing number to report it under and no expenditure to measure. That is why the SEFA question and the single audit question have the same answer for PPP, and why forgiveness does not change it: forgiveness is the loan being cancelled, not a new federal award being expended.
Source: 2 CFR 200.510 · 2 CFR 200.502 · Last verified: 2026-09-20
What to do before your audit
- List every federal source you touched in the year: direct awards, pass-through awards from a state or city, loans, and non-cash assistance.
- For each one, find the Assistance Listing number and the agency page or Supplement section.
- Keep PPP documentation anyway — the forgiveness file, the application and the payroll support are still records your auditor may ask to see.
- Ask your auditor to put their PPP conclusion in the engagement letter or the planning memo, with the Supplement edition they relied on.
Source: 2 CFR 200.502 · OMB Compliance Supplement · Last verified: 2026-09-20
Questions and answers
Are PPP funds subject to single audit?
On the sources we can open, no. SBA's COVID-era page sets a Single Audit Act requirement for nonprofit COVID-19 EIDL borrowers and states nothing equivalent for PPP, and the SBA part of the current Compliance Supplement has no PPP program section.
Are PPP loans subject to single audit for a nonprofit borrower?
We found no official statement putting PPP loans into the single audit scope for nonprofit borrowers. The audit trigger is federal awards expended under 2 CFR 200.501, measured on the schedule of expenditures of federal awards.
Does a PPP loan trigger a single audit if we also received EIDL?
The EIDL money is what SBA addresses. A nonprofit COVID-19 EIDL borrower that expended enough federal money in the year, counting other federal awards, falls under the Single Audit Act in the year the loan funds are spent.
Work out your own position in two minutes: check the single audit threshold.
This is public-record information, not accounting or legal advice.