Supporting Statement A

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U.S. Small Business Administration
SBA Unified Certification System
OMB Control No. 3245-0374
Part A - SUPPORTING STATEMENT

 
A:  JUSTIFICATION 

On June 11, 2026, SBA published a Notice of Proposed Rulemaking titled, “Reforms To Remove SBA's 8(a) Program's Rebuttable Presumption of Social Disadvantage for Individually Owned Firms Only; Reforms Do Not Impact Entity-Owned Firms”
(91 FR 35433). As part of this rule, SBA is proposing revisions to the application for entry to the 8(a) Business Development Program. SBA proposes replacing the current regulatory tests for social disadvantage with a new test. Specifically, SBA proposes a test by which an American citizen can establish social disadvantage by showing that within his or her lifetime, the federal or a state or local government or a university or corporation, through any action, policy, rule, regulation, or other practice of any of its agencies, subsidiaries, or authorized agents, discriminated or was biased against a clearly definable racial, ethnic, or cultural group of which the citizen is a member, or favored in any way a racial, ethnic, or cultural group of which the citizen is not a member, and that the discrimination, bias, or harm materially harmed the citizen.  To establish the American citizen was himself or herself harmed by such discrimination, prejudice, or bias, the citizen may self-certify that he or she was a member of the relevant group at the time of the government’s or private entity’s action or during the effective period of the relevant action, policy, rule, regulation, or other practice, and that such action, policy, rule, regulation, or other practice materially harmed them.  

This rule would not change the application process for HUBZone, WOSB/EDWOSB, or VOSB/SDVOSB.

1.  Circumstances necessitating the collection of information

SBA is required by statute to administer four small business government contracting programs: the 8(a) Business Development (15 USC 637(a); 13 CFR 124); Historically Underutilized Business Zone (HUBZone) (15 USC 657a; 13 CFR 126); Veteran-Owned/Service-Disabled Veteran-Owned Small Business (VOSB/SDVOSB) (15 USC 657f and 657f-1;13 CFR 128); and Women-Owned/Economically Disadvantaged Women-Owned Small Business (WOSB/EDWOSB) (15 USC 637(m); 13 CFR 127) programs. In order to participate in these programs, small businesses must apply to SBA and receive certifications for each program. Previously, it was required that applications for each program certification be submitted separately. All of the applications for certification are overseen by SBA’s Government Contracting and Business Development (GCBD) staff and are submitted electronically. Previously, each program had a unique web address and online portal, but now the unified certification application is available on certification.sba.gov. This information collection has combined applications and certifications of these programs into one system, certification.sba.gov. By having one system, the process is easier for small businesses to apply for one or all of the certifications in a streamlined manner.

This information collection also includes a HUBZone Calculator. The HUBZone Calculator in the Unified Certification System provides a user-friendly way for applicants to enter information about their employees' work hours and work locations and where they live, if they are claiming an employee as a HUBZone resident employee. After entering the information in the HUBZone Calculator, applicants can easily see whether they meet the program's eligibility requirements and if they do not, see where the deficiencies are so that they may be prepared to submit a successful application in the future. The HUBZone Calculator eases the burden on HUBZone participants.

2.  How, by whom, and for what purpose information will be used
Small businesses applying to SBA for certification in the 8(a), HUBZone, VOSB/SDVOSB, and WOSB/EDWOSB programs must complete an electronic application. SBA uses the information submitted on the application to verify a concern’s eligibility for the programs and for updating the database of certified small business concerns. SBA also uses the information for the recertification process and for program examinations to verify continuing eligibility for government contracting.
 
3.  Technological collection techniques  
All the information related to applications for certification in SBA’s programs are completed electronically. After submission of the electronic application, SBA requires each firm to sign a “attestation document” attesting that all the information is true and correct. Electronic transmission of the information provides an efficient way to process and collect the necessary data and reduces the burden on the program participants by saving them time and expense of submitting paper files. All responses are collected electronically.

4.  Avoidance of Duplication
SBA has created one unified certification system for all of the certification programs. This will allow a small business concern to apply for all certification programs for which they qualify at one time without needing to provide redundant information. For example, a WOSB that is also a VOSB can apply for both certification programs in one system. By having firms submit their documents in one system, the process eliminates any duplicative or unnecessary questions. SBA combined the information collections of 8(a), HUBZone, VOSB/SDVOSB, and WOSB/EDWOSB into one information collection to minimize the collection burden on small businesses applying to SBA for certification in the programs. 

5.  Impact on small businesses or other small entities
	SBA has combined the information collection for 8(a), HUBZone, VOSB/SDVOSB, and WOSB/EDWOSB into one information collection. This will reduce the impact on small businesses because submission of documents electronically will be required only one time for application for all program certifications. Therefore, this information collection will not have a significant economic impact on a substantial number of small businesses. The collection of this data involves small businesses, but not governmental jurisdictions or not-for-profit enterprises. With respect to small businesses, the information requested is commercial information that should be maintained by a small business performing on, or seeking to perform on, Federal contracts. All respondents are expected to be small businesses.

6.  Consequences if collection of information is not conducted
If SBA does not collect this information, it cannot fulfill its statutory mandates to authorize and oversee certification of small businesses in the different programs. 

7.  Existence of special circumstances
No special circumstances exist.
 
8.  Solicitation of Public Comment
	SBA published a request for comments in the Notice of Proposed Rulemaking published on June 11, 2026, at 91 FR 35433. All comments must be identified by Docket No. SBA-2026-0133, by the Federal eRulemaking Portal at regulations.gov or through mail.

9.  Payment of gifts
No payments of gifts will be provided.

10.  Assurance of Confidentiality 
Business information for the purpose of certification does not consist of any proprietary trade secrets or confidential information. SBA’s Cybersecurity and Privacy Policy defines the security protections for Controlled Unclassified Information (CUI) and sensitive information. All information and/or documents submitted will be protected to the fullest extent permitted by the Privacy Act, and Freedom of Information Act, 5 U.S.C. 552.
SBA is collecting only the minimum information required to determine an applicant is eligible for certification. Written consent is obtained through electronic certification to authorize SBA’s collection of such information on each SBA form.
The questions contained in this information collection include Personally Identifiable Information (PII). PII is protected in accordance with SBA Cybersecurity and Privacy Policy, federal policies, guidelines, industry practices and standards which consists of encryption, access controls, least privileges, role-based permissions, Cybersecurity Awareness Training for all SBA staff, signed Rules of Behavior, and data minimization. The Government Contracting and Business Development System is governed by SORN SBA 30 (86 FR 19078, April 12, 2021). Also, the information collected is protected to the extent permitted by law including the Freedom of Information Act and the Privacy Act, where applicable. SBA provides respondents with a summary statement of the laws governing the Agency’s protection and disclosure of confidential and sensitive information as part of SBA Form 2413. SBA restricts access to the information to those personnel with a need to know. 
The information collected subject to these privacy laws are required to obtain an SBA certification. All information submitted to SBA through the electronic application system is protected by SBA’s electronic security controls in accordance with National Institute of Standards and Technology.
SBA’s System of Records Notifications (SORN) are found at https://www.sba.gov/about-sba/open-government/privacy-act/privacy-act-system-records-notices-sorns. 
SBA’s Privacy Impact Assessments are found at the following location: https://www.sba.gov/documents?query=privacy+impact+assessment&type=51.

11.  Questions of a sensitive nature
This collection may contain questions that individuals perceive to be of a sensitive nature. This information is necessary to determine if an individual qualifies for certification. This information is protected to the extent permitted by law as outlined in the previous section.

12.  Estimate the hourly burden of the collection of information
	The number of applications submitted using SBA Form 2413 is estimated to be about 29,329 annually. The estimated average time to complete an application is approximately 80 minutes. This was determined by calculating the weighted average of the FY23 data. Thus, the total burden hours are calculated at 39,330 hours. The estimated annualized cost to the applicant for SBA’s information collection is estimated at $2,519,480. This calculation is based on 39,330 hours times $64.06 (approximate wage rate for Federal government employees at a GS-13, Step 51 level who would submit an application). This is representative of an average wage of individuals completing this form.

Burden per Response: 
  
Time Per Response 
Cost Per Response 
Reporting 
Approx. 80 minutes
$85.90
Record Keeping 
0
0
Third Party Disclosure 
0
0
Total 
  80 min
85.90
 
Annual Burden: 
  
Annual Time Burden (Hours) 
Annual Cost Burden
(Dollars) 
Reporting 
39,330
$2,519,480
Record Keeping 
0
0
Third Party Disclosure 
0
0
Total 
39,330

$2,519,480




13.  Estimate the total annual cost burden for submission
	There are no capital or start-up cost components, nor are there any operation or maintenance and purchase of services components associated with this information collection.

14. Annualized Cost to the Federal Government
	The average amount of time for SBA employees to review and make a determination regarding certification is expected to be 3 hours.The estimated annual cost to the Federal government of this information collection is $5,636,447, calculated as follows:

	29,329 applicants x 3 hours = 87,987 hours

	87,987 hours x $64.062= $5,636,447

15.  Explanation of program changes in Items 13 or 14 on OMB Form 83-I
	There are no changes to the annual burden estimates as a result of the rulemaking.

16. Collection of information whose results will be published.
No publishing is planned. 
 
17. Expiration date for collection of information
SBA will display the expiration date.

18.  Exceptions to certification in block 19 on OMB Form 83-I
There are no exceptions to the certification statement.

Part B: Collection of Information Employing Statistical Methods. 
This collection of information is not a survey and does not employ statistical methods.