New Annual Reporting Requirements for Grow NJ Tax Incentive Recipients

The New Jersey Economic Development Authority (NJEDA) officially updated the reporting requirements for Grow NJ tax incentive recipients in November 2025. Effective for report submissions due April 30, 2026, and thereafter, the most significant change is the shift from a simple CFO certification to a mandatory Agreed-Upon Procedures (AUP) report performed by an independent Qualified CPA that has been approved by the NJEDA.

The New Compliance Standard: What Grow NJ Recipients Need to Know

For years, Grow NJ beneficiaries managed annual compliance internally. However, under the new N.J.A.C. 19:31-18.11 regulations, the NJEDA now requires a higher level of third-party verification. This AUP engagement is designed to provide the Authority with independent comfort that your company is meeting its job creation, retention, and statewide workforce requirements.

Failure to submit this report within 120 days of your tax privilege period can result in the forfeiture of your tax credits for that year.  Although there will be some leeway this first reporting year for CPA AUP report submissions past the deadline, company payroll submissions are still due within the deadline. The NJEDA will not begin to review and process any Grow NJ tax incentives until they are in receipt of the CPA AUP report for the recipient.

Core Requirements of the AUP Engagement

A NJEDA approved CPA must now perform specific procedures to satisfy GROW NJ annual reporting requirements including:

• Full-Time Employee (FTE) Counts: Validating the number of new and retained positions at the qualified business facility.
• Statewide Workforce Totals: Ensuring the company maintains at least 80% of its pre-approval New Jersey workforce.
• Wage Verification: Confirming that employees meet the minimum salary requirements and are subject to NJ Gross Income Tax.
• Affiliate Tracking: Identifying any affiliates contributing to the FTE count that were not in the original application.

Unlike a standard audit, an Agreed-Upon Procedures report is highly technical and follows a checklist approach defined by the NJEDA.

How Citrin Cooperman Can Help

We have 10 years of experience working with the NJEDA on GROW NJ AUP reports as well as other related NJEDA programs and incentives. We understand the nuances of NJEDA’s expectations.

Our team provides a streamlined process to ensure your Grow NJ credits remain secure:

• NJEDA Liaison: We use the exact AUP language and templates acceptable to the Authority.  We have contacts with the NJEDA and work with them to make sure any of their concerns are addressed proactively.
• Payroll Data Scrubbing: We review WR-30s and internal payroll records to identify potential FTE discrepancies before they become issues.
• 80% Threshold Monitoring: We proactively calculate your statewide workforce ratios to ensure you don't accidentally fall below the forfeiture limit.
• Accelerated Reporting: We prioritize your engagement to meet the 120-day filing window.

The Grow NJ program is a powerful engine for your company’s growth, but the new administrative burden can be significant. By engaging a qualified professional who understands the specific NJEDA procedures, you turn a compliance challenge into a seamless annual process.

To learn more on how we can help, please contact Salvatore Leone or Alex Berkovich.  We are happy to set up a call to discuss these new reporting requirements in greater detail and answer any questions you may have.