On September 11, 2026 the SBA published a notice with one of the least clickable titles in the Federal Register: “Privacy Act of 1974; Matching Program.” Read past the title, though, and it’s the agency writing down, in public, which programs it will now run through the Treasury’s Do Not Pay system.
The list includes the Paycheck Protection Program. The PPP, per the SBA’s own website, “ended on May 31, 2021.”
What Do Not Pay is
Do Not Pay is a Treasury system run by the Bureau of the Fiscal Service. An agency sends it names and taxpayer numbers, and it checks them against federal databases, like the list of people barred from federal awards, federal debt records and death records. If there’s a hit, the agency gets a flag and decides what to do. The notice says the whole point is to verify eligibility through Do Not Pay before a payment or an award is made. You check before the money goes out.
What the new notice covers
The last version, from October 10, 2023, described screening for four program families: disaster home loans, business and economic injury disaster loans, 7(a) loans and 504 loans.
The 2026 version replaces it. Its appendix lists 19 program entries, including:
- 7(a) and 504 loan approvals, plus the SBA’s purchases of those guarantees
- Disaster loans, and the COVID EIDL program
- EIDL Emergency Advances, Targeted EIDL Advances and Supplemental Targeted Advances
- PPP loan forgiveness and PPP guaranty purchases
- The Restaurant Revitalization Fund and the Shuttered Venue Operators Grant
- Microloans, the Intermediary Loan Program, Prime Technical Assistance, SBIC approvals and purchases, and Surety Bond Guarantees
The records it can send over got a lot broader too. Beyond names, addresses and taxpayer numbers, the list now includes bank information, credit information, payment history, collateral filings, “investigative reports” and “compliance and enforcement information on individuals named in any business loan and/or awardee files throughout the life of SBA’s interest in any loan.”
Comments are due by October 8, 2026 under docket SBA 2026 0298 on regulations.gov. The program takes effect 30 days after publication and runs through September 10, 2029.
We already know what happened without it
This isn’t a hypothetical. On January 11, 2021, the SBA Inspector General sent the agency a management alert after Treasury’s Do Not Pay team ran PPP loan data that the OIG handed over. As of August 8, 2020, the SBA had approved 5.2 million PPP loans worth $525 billion. Treasury’s analysis found 57,473 of those loans matched a Do Not Pay record indicating the borrower may have been ineligible. Those loans totaled about $3.6 billion, and $280 million of it hadn’t even been sent out yet.
The OIG put the cause plainly. It believed the loans went to potentially ineligible recipients because the SBA and its lenders took applicants at their word, relying on what borrowers certified about their own eligibility. The SBA told the OIG it had developed systems to screen borrowers against Do Not Pay before the alert. The OIG wrote that the claim “does not match” what it found.
The SBA’s fix back then was to put “hold” flags on the matched loans so they’d get reviewed before forgiveness or any further disbursements. In other words, for all but that $280 million, the screening happened after the money was already out the door.
Checking the receipt, five years later
So what does it mean to add PPP to a prepayment screening notice in 2026?
The SBA’s PPP page says borrowers can apply for forgiveness up to five years from the date the SBA issued their loan number. The program ended May 31, 2021. By that math, the five year forgiveness window for the last PPP loans would have closed around the end of May 2026, several months before this notice was published. The PPP entry that plainly still involves money going out is guaranty purchases, where the SBA buys its guarantee from a lender on a loan that went bad.
That’s still worth doing. Every guaranty purchase is taxpayer money going out, and checking it is better than not checking it. The same goes for going back through Restaurant Revitalization Fund and Shuttered Venue grant files for recovery work, which the notice explicitly lists as a purpose.
But the program list is also a timeline of what wasn’t screened through Do Not Pay when it counted. The OIG’s 2021 alert showed $3.6 billion in matched loans approved on borrowers’ own word. A 2026 notice promising to verify PPP eligibility before payment is, for most of that program, a prepayment check arriving about five years after the payments.
If you have a view on the SBA sending investigative files and loan histories to Treasury through 2029, you have until October 8 to say so. Unlike last month’s rule on public comment, this one actually asked.
