A 504 application passes four eligibility screens — size, occupancy, jobs and project — and this page owns exactly those four, with the rules as they stand in October 2026. Pricing, loan structure and the 504-vs-7(a) decision are deliberately not here: they live in Phase 1’s 504 rates and fees page, the 504 calculator and the comparison hub. One warning first: this SERP is two rule-changes behind. Most ranking pages still quote a $75,000-per-job figure and $15M/$5M size limits. Both are stale.
General information, not financial advice or a loan offer. Rules per 13 CFR Part 120 Subpart H and the September 30, 2025 Federal Register job-standard notice, as reviewed October 2026.
Underneath the four screens sit the universal ones (§120.100): an operating, for-profit, U.S.-located business that can demonstrate need, plus the March 2026 ownership rule — 100% U.S. citizens/nationals. Subpart H adds the borrower rule (§120.801): the borrower must use the Project Property itself, or be an Eligible Passive Company leasing it to an Operating Company. The eligibility hub runs the universal set; here are the 504-specific four.
You and your affiliates must meet a §121.301(b) size standard, through either door:
Read carefully if you cross-check on SBA.gov: the SBA’s own 504 page still prints the old figures — tangible net worth under $15 million, average net income under $5 million. The regulation controls. 13 CFR 121.301(b)(2) sets $20M/$6.5M for both 7(a) and the 504 program, and that is the standard your CDC applies.
The borrower must occupy the property, permanently, at these levels:
If an Eligible Passive Company holds the property (§120.111), the tests are met through the Operating Company it leases to. The EPC structure has its own eligibility terms: the lease must be written and subordinate to the SBA’s lien, rent is capped at the loan payment plus direct holding expenses, the Operating Company must be a guarantor or co-borrower, and every 20%+ holder of either entity guarantees.
A 504 exists to create jobs, and the project must create or retain one job per $95,000 of SBA-guaranteed debenture. Two categories get the relaxed ratio of one job per $150,000:
Jobs are counted as created or retained within two years of funding. The $75,000 standard figure (and $85,000/$100,000/$120,000 variants) still quoted across the web are the pre-2023 and 2023 numbers — the September 30, 2025 Federal Register notice (90 FR 47117) replaced them.
Can’t meet the ratio? The project may still qualify under a §120.862 community-development or public-policy goal — the list runs from business-district revitalization, exports, and women-, veteran- and minority-owned business expansion to rural development, an energy-consumption reduction of at least 10%, and sustainable design — provided the CDC’s overall portfolio meets its required job average. For goal projects, and for projects in Alaska, Hawaii, enterprise/empowerment zones, enterprise communities, Labor Surplus Areas and Opportunity Zones, that portfolio may average up to $150,000 per job.
The project must be fixed assets: land, buildings, construction or renovation, and fixed assets with a useful life of at least 10 years at a fixed location (§120.120(a)). Two hard edges:
Debenture size caps ($5 million; $5.5 million for manufacturing and energy projects) are loan structure, not eligibility — one line here, the detail on the rates and fees page.
On credit: there is no SBA 504 credit-score floor — your CDC must obtain and review credit reports on the applicant, guarantor-owners and guarantor affiliates, and the score picture is covered on the credit score page.
Am I eligible? You are, if you clear the universal screens (operating, for-profit, U.S.-located, citizen-owned, demonstrable need) plus all four here: small under §121.301(b) — remembering the standard is $20M/$6.5M, whatever SBA.gov’s 504 page prints — at least 51% (existing) or 60% (new construction) occupancy, one job per $95,000 of debenture (or a §120.862 goal with a compliant CDC portfolio), and a fixed-asset project with no working capital in it.
What are the requirements for an SBA 504 loan? The four screens above, in order: size, occupancy, jobs, eligible project — plus a CDC willing to certify the package and a senior lender for the first-mortgage half. Rates, equity tiers and timelines are structure, covered on the Phase 1 504 rates and fees page.
Can an SBA 504 loan be used for working capital? No. Section 120.120(b) limits working-capital uses to 7(a) and microloan proceeds; a 504 funds fixed assets only. If your project mixes property with working capital, the usual shape is a 504 for the asset and a 7(a) for the rest — the comparison hub walks through the split.
How much down payment does an SBA 504 loan require? That is loan structure, not an eligibility screen, so this page doesn’t carry it — the equity tiers (10/15/20% by asset type and business age) are on the Phase 1 504 rates and fees page and the property page, and the 504 calculator runs your project’s numbers.
General information, not financial advice or a loan offer. Sources: 13 CFR §§120.100, 120.110, 120.111, 120.120, 120.131, 120.801, 120.861, 120.862, 121.301; Federal Register notice, September 30, 2025, 90 FR 47117 (Docket SBA-2025-0135); SBA.gov 504 loans page (size figures noted as stale against the CFR). Currency verified 2026-10-23.