New NJEDA Reporting Regulations for Grow New Jersey Program Recipients: What Companies Need to Know for 2025 and Beyond

The New Jersey Economic Development Authority (NJEDA) has adopted new reporting regulations under N.J.A.C. 19:31-18.11 that significantly change the annual compliance obligations for companies receiving tax credits under the Grow New Jersey Assistance Program.  

These changes are effective for reporting periods ending December 31, 2025, with annual submissions due April 30, 2026, and will require award recipients to engage an independent CPA qualified by the NJEDA to perform an Agreed-Upon Procedures (AUP) engagement. EisnerAmper is considered a Qualified CPA firm by the NJEDA. 

Overview of the Updated Reporting Requirements 

Historically, Grow New Jersey recipients satisfied annual reporting requirements through an internally prepared report certified by company management, typically the chief financial officer. Under the revised regulations, the NJEDA has moved toward enhanced third-party verification to strengthen oversight and accountability. The updated rules require an Agreed-Upon Procedures report issued by a qualified, independent CPA, rather than reliance solely on management certification. 

Pursuant to N.J.A.C. 19:31-18.11, businesses that have received Grow New Jersey awards must submit an annual report that includes, among other items: 

• Information on full-time employees at the qualified business facility 
• Statewide workforce totals in New Jersey 
• Details regarding affiliates contributing to employment counts 
• Certifications of compliance with the incentive agreement and program requirements 

Most notably, the updated rules require an Agreed-Upon Procedures report issued by a qualified, independent CPA, rather than reliance solely on management certification.  

What Changed From the Prior Rules 

The most significant regulatory change is the shift from self-certification to CPA-performed procedures. The CPA does not issue an opinion, as would be done in an audit or review, but instead performs and reports on specific procedures to be accepted by the NJEDA. The results are presented in an agreed-upon procedures report that the Authority uses to evaluate ongoing compliance with program requirements.  

This enhanced reporting standard is designed to provide NJEDA with greater assurance that recipients continue to meet key conditions of their Grow New Jersey awards, including job creation or retention thresholds and statewide employment maintenance requirements. For the 2025 tax year, failure to timely submit the CPA AUP report may delay receipt of the tax credit for the year and, going forward, could result in the forfeiture of tax credits for the applicable period.  

Key Elements of the Agreed-Upon Procedures Engagement

While the exact procedures must be accepted by the NJEDA, AUP engagements under the Grow New Jersey program address: 

• Verification of full-time employee counts at the qualified location 
• Validation of statewide New Jersey workforce levels 
• Testing of employee wages and New Jersey tax status 
• Identification of affiliate entities contributing to employment metrics 

Because of the specificity of the procedures, experience with NJEDA incentive programs and familiarity with the Authority’s expectations are critical to completing the engagement efficiently and accurately.  

How EisnerAmper Can Help 

EisnerAmper has 15 years of extensive experience assisting companies participating in New Jersey economic incentive programs. Our professionals understand the technical requirements of NJEDA-approved Agreed-Upon Procedures engagements and the documentation standards necessary to support continued Grow New Jersey compliance in the years to come. 

We have a direct line of communication with the NJEDA, and liaise between them and  clients to:

• Interpret NJEDA AUP reporting requirements 
• Perform AUP engagements aligned with regulatory expectations 
• Identify and resolve potential compliance issues proactively 
• Meet tight annual filing deadlines 

As these new regulations take effect, planning and proactive communication will be essential. EisnerAmper is well-positioned to help Grow New Jersey recipients navigate the updated reporting landscape and protect the value of their tax credit awards. 

For more information, please contact Joe DiFalco or Douglas Graham, or connect with our team using the form below.