What documents do I need to keep for PPP loan forgiveness?

This article outlines the general documents you'll need to retain for PPP Loan Forgiveness. The documents are separated by form. To determine which form to use, review our What PPP loan forgiveness forms are available? support article. You may also refer to the SBA’s PPP forgiveness page for complete guidance and details.

Documents You Must Retain (But Do Not Need to Submit)

Form 3508S

• Documentation verifying eligible cash compensation and non-cash benefit payments from the covered period, including each of:
  • Bank account statements or third-party payroll service provider reports documenting the amount of cash compensation paid to employees.
  • Tax forms (or equivalent third-party payroll service provider reports) for periods that overlap with your covered period:
    • Payroll tax filings reported (or that will be reported) to the IRS (typically, Form 931), and
    • State quarterly business and individual employee wage reporting and unemployment insurance tax filings reported (or that will be reported) to the relevant state.
    • Payment receipts, canceled checks, or account statements, showing the amount of employer contributions to employee group health, life, disability, vision, or dental insurance and retirement plans that you included in your forgiveness amount.

For non-payroll expenses you include in your forgiveness application:

• For business mortgage interest payments, provide both:
  • Docs verifying the existence of obligations before Feb 15, 2020, and
    • • Either:
        • Copy of lender amortization schedule and receipts or canceled checks verifying eligible payments from the covered period, or 
        • Lender account statements from Feb 2020 and from your covered period plus one month verifying both interest amounts and eligible payments.

For business rent/lease payments, both:

• Docs verifying the existence of obligations before Feb 15, 2020, and
  • Either:
    • Copy of current lease and receipts or canceled checks verifying the eligible payments from your covered period, or
    • Lessor account statements verifying eligible payments from Feb 2020 and from your covered period plus one month.

For business utility payments, both:

• Docs verifying the existence of obligations before Feb 15, 2020, and
• Copy of invoices from Feb 2020 and your covered period, and
• Receipts, canceled checks, or account statements, verifying those invoiced payments.

For covered operations expenditures:

• Copy of invoices, orders, or purchase orders paid during the covered period, and
• Receipts, canceled checks, or account statements.

For covered property damage costs:

• Copy of invoices, orders, or purchase orders paid during the covered period, and
• Receipts, canceled checks, or account statements, verifying those eligible payments, and
• Documentation that the costs were related to property damage and vandalism or looting due to public disturbances that occurred during 2020 and such costs were not covered by insurance or other compensation.

For covered supplier costs:

• Copy of contracts, orders, or purchase orders in effect at any time before the covered period (except for perishable goods), and
• Copy of invoices, orders, or purchase orders paid during the covered period, and
• Receipts, canceled checks, or account statements verifying eligible payments.

For covered worker protection expenditures:

• Copy of invoices, orders, or purchase orders paid during the covered period, and
• Receipts, canceled checks, or account statements verifying those eligible payments, and
• Documentation that the expenditures were used by the borrower to comply w/ the applicable COVID-10 guidance during the covered period.

All other records relating to your PPP loan, including documentation:

• You submitted with your PPP loan application
• Supporting your certification that the loan was necessary
• Supporting your PPP eligibility (including, for Second Draws, your certification of gross receipt reduction)
• Supporting your loan forgiveness application
• Your material compliance with PPP requirements.

Important: If you’re using Form 3508S, you must retain all employment records/payroll documentation for four years, and all other documentation for three years from the date your loan is forgiven or repaid. Upon request, you must provide these documents.

Form 3508EZ

• Documentation supporting the certification that salaries and wages were not reduced by 25% during your covered period relative to the most recent full quarter before your covered period.
  • This must include payroll records that separately list each employee and show amounts paid to each employee during the most recent full quarter before your covered period, and amounts paid to each employee during the covered period.
    

As applicable, documentation showing:

• Any employee job offers and refusals, refusals to accept the restoration of reduced hours, firings for cause, voluntary resignations, and/or written employee requests for reduction in work schedule, and
• Any inability to hire similarly qualified employees for unfilled positions on or before (i) Dec 31, 2020 (for PPP loans made before Dec 27, 2020) or (ii) the last day of the covered period (for PPP loans made after Dec 27, 2020).

If applicable, documentation supporting the certification that you did not reduce the number of employees or average paid hours of employees between Jan 1, 2020, and the end of your covered period:

• Do not include reductions that arose from an inability to rehire individuals who were employees on Feb 15, 2020, if you were unable to hire similarly qualified employees for unfilled positions on or before Dec 31, 2020 (or the last day of your covered period for loans made after Dec 27, 2020).
• These documents must include payroll records that separately show each employee and the amounts paid to each employee between Jan 1, 2020, and the end of your covered period.

If applicable, documentation supporting the certification that you were unable to operate between Feb 15, 2020, and the end of your covered period at the same level as before Feb 15, 2020, due to compliance or guidance issued by the Secretary of Health and Human Services, Director of the CDC, or OSHA related to standards of sanitation, social distancing, or other work or customer safety requirements related to COVID-19:

• The compliance or guidance must have been issued between:
  • Mar 1, 2020, and Dec 31, 2020, for PPP loans made before Dec 27, 2020, or
  • Mar 1, 2020, and the last day of the covered period for PPP loans made after Dec 27, 2020.
    
• This documentation must include copies of the applicable requirements for each of your business locations and your relevant financial records.

All other records relating to your PPP loan, including documentation:

• You submitted with your PPP loan application,
• Supporting your certification that the loan was necessary
• Supporting your PPP eligibility (including, for Second Draws, your certification of gross receipt reduction)
• Supporting your loan forgiveness application
• Your material compliance with PPP requirements.

Important: If you’re using Form 3508EZ, you must retain these documents for six years from the date your loan is forgiven or repaid. Upon request, you must provide these documents.

Form 3508

• PPP Schedule A worksheet or equivalent
• Documentation supporting the listing of each individual employee in Schedule A Worksheet Table 1, including “Salary/Hourly Wage Reduction” calculation, if necessary.
• Documentation supporting the listing in Schedule A Worksheet Table 2 for each individual employee that received annualized comp of more than $100,000 in any single pay period in 2019.

As applicable, documentation showing:

• Any employee job offers and refusals, refusals to accept the restoration of reduced hours, firings for cause, voluntary resignations, and/or written employee requests for reduction in work schedule, and
• Any inability to hire similarly qualified employees for unfilled positions on or before (i) Dec 31, 2020 (for PPP loans made before Dec 27, 2020) or (ii) the last day of the covered period (for PPP loans made after Dec 27, 2020).

If applicable, documentation supporting the certification that you were unable to operate between Feb 15, 2020, and the end of your covered period at the same level as before Feb 15, 2020, due to compliance or guidance issued by the Secretary of Health and Human Services, Director of the CDC, or OSHA related to standards of sanitation, social distancing, or other work or customer safety requirements related to COVID-19:

• The compliance or guidance must have been issued between:
  • Mar 1, 2020, and Dec 31, 2020, for PPP loans made before Dec 27, 2020, or
  • Mar 1, 2020, and the last day of the covered period for PPP loans made after Dec 27, 2020.
• This documentation must include copies of the applicable requirements for each of your business locations and your relevant financial records.
• Documentation supporting Schedule A Worksheet “FTE Reduction Safe Harbor 2”

All other records relating to your PPP loan, including documentation:

• You submitted with your PPP loan application,
• Supporting your certification that the loan was necessary
• Supporting your PPP eligibility (including, for Second Draws, your certification of gross receipt reduction)
• Supporting your loan forgiveness application
• Your material compliance with PPP requirements.

Important: If you’re using Form 3508, you must retain these documents for six years from the date your loan is forgiven or repaid. Upon request, you must provide these documents.

The information, opinions, and advice in this post are provided for educational purposes only and do not necessarily state or reflect those of Bluevine and/or its partners, including Celtic Bank. Neither Bluevine nor its partners are responsible for the accuracy of any content provided by author(s) or contributor(s). For information about Bluevine products and services, please visit the Bluevine FAQ page. For information about the Paycheck Protection Program, please visit the SBA’s page.