SBA Loan Requirements 2025: What Borrowers Must Know

By Susan Lamping, VP of Sales, and Andrew Mort, SBA 504 & CRE Sales Manager

The U.S. Small Business Administration (SBA) has made changes to the 2025 SBA loan application requirements, and both borrowers and lenders need to understand what’s required to stay compliant and move forward quickly. Whether you’re working on a 7(a) loan application or a 504 loan application, new procedural notices from SBA affect which documents and information must be submitted and when.

Staying ahead of the 2025 SBA loan application requirements can help avoid delays and confusion for both borrowers and lenders. Below, we break down what is new, what you will need to prepare, and how CDC Small Business Finance (part of the Momentus Capital branded family of organizations) can help guide you through the process.

Summary Checklist of the 2025 SBA Loan Application Requirements

For Borrowers

Date of Birth for all owners
Ownership structure (100% Beneficial Ownership by citizens of the U.S., U.S. Nationals, or those who are Lawful Permanent Residents (LPRs)
Citizenship or LPR documentation
Alien registration numbers (if applicable)
SBA environmental review (if real estate is involved)
SBA guaranty fees for 7(a) loans (based on loan amount)

For Lenders

Collect and enter Dates Of Births in E-Tran
Verify Beneficial Ownership (81% minimum)
Document eligibility and USCIS verification
Certify environmental compliance
Maintain full records in loan file

2025 SBA Loan Application Requirements: Key Changes Explained

Recent SBA procedural notices introduce three key updates to stay compliant with the 2025 SBA loan application requirements. These updates reflect a broader shift in how the SBA is managing loan application requirements in 2025. Here is a breakdown for small business borrowers and the lenders that support them.

1. Date of Birth is Required in E-Tran

As of March 27, 2025, SBA now requires all lenders to submit the date of birth for every owner of the applying business in the SBA’s E-Tran system. Until official forms are updated, this information must be manually collected and entered.

2. Stricter SBA Environmental Review Standards

The SBA is changing the way they review environmental reports for 7(a) loan applications and 504 loan applications..

If no contamination is identified, it is the lender’s responsibility to certify this and to maintain the environmental investigation report in the loan file.
For properties with contamination, and if and the Lender still wishes to make the loan, then the SBA Lender must comply with the Environmental Policies and Procedures requirements of SOP 50 10 7.1

3. SBA Citizenship & Ownership Documentation

Lenders must document that the business is 100% owned by U.S. citizens or Lawful Permanent Residents (LPRs). Citizenship must be fully documented and confirmed as eligible at the time of application.

Eligibility Criteria

Business owners need to be 100% U.S. citizens or Lawful Permanent Residents (LPRs). Owners must not include undocumented individuals, visa holders, or other ineligible persons.
Alien registration numbers (if applicable) must be collected and entered in E-Tran.

4. SBA Guarantee Fees Reinstated for 7(a) Loans

After several years of waivers, the SBA has reinstated its upfront guarantee fees for 7(a) loans. These fees vary based on loan size:

Loans up to $150,000	2% of the guaranteed portion
Loans $150,001–$700,000	3%
Loans above $700,000	Tiered rates between 3.5–3.75%. Short-term loans (under 12 months) are subject to a 0.25% fee. Lenders also pay an annual service fee of 0.55%, which cannot be passed on to borrowers.

Here’s a Summary Checklist of the 2025 SBA Loan Application Requirements

For Borrowers

Date of Birth for all owners
Ownership structure (must total 100%)
Citizenship or LPR documentation
Alien registration numbers (if applicable)
Environmental review (if real estate is involved)

For Lenders

Collect and enter DOBs in E-Tran
Verify Beneficial Ownership (81% minimum)
Document eligibility and USCIS verification
Certify environmental compliance
Maintain full records in loan file

What is the new SBA rule about beneficial ownership?

The SBA now requires that lenders list at least 81% of beneficial owners in E-Tran when submitting a loan application. A beneficial owner includes anyone with direct or indirect ownership. This move ensures compliance with federal law.

Borrowers must certify that none of the listed owners are ineligible, and lenders must verify SBA loan documents before submission.

What SBA loan documents do you need in 2025?

As a borrower, understanding the updated 2025 SBA loan application requirements can help you avoid delays. You can help your loan move faster by preparing the following:

Date of birth for each owner

Citizenship or lawful permanent residency documentation

Clear list of all owners and ownership percentages

Recent (less than 1-year-old) environmental reports for real estate-backed loans

Any applicable alien registration numbers or supporting USCIS documents

Funds for applicable SBA guarantee fees (7(a) loans only)

What should lenders be asking borrowers?

If you’re a lender or broker supporting a borrower, ensure you collect:

Date of births for all owners
Alien registration numbers and verification (as required)
Up-to-date environmental investigations with the correct certifications
Reliance letters and records to meet SBA environmental guidelines
Fee calculations and payments for SBA guaranty fees

These details are essential to ensure compliance with the 2025 SBA loan application requirements.

How CDC Small Business Finance Can Help

CDC Small Business Finance is here to make SBA lending simpler for everyone involved.

SBA 504 Loan Application

You can use an SBA 504 loan to buy, construct, or improve commercial real estate or to purchase heavy equipment. See our list of questions to consider when comparing buying vs. leasing.

SBA 7(a) Loan Application

We help small business owners like you get a loan to support your business dreams through various products so that you can get the best loan to meet your needs. Read about what you can use this financing for.

Additional Resources

Have questions? Our team stays up to date on SBA loan documents changes. Get in touch with our loan experts.

If you’re unsure how to start or need help navigating the 2025 SBA loan application requirements, our Small Business Advisors are here to support you with expert guidance and hands-on help.