The SBA has provided some guidance regarding the requirement for borrowers to certify their economic need for a PPP loan.
If the loan amount is under $2m, then the loan will fall under safe harbor and will not need to be certified. The SBA has stated that it will not be able to review these smaller loans due to their limited resources, and such borrowers will be deemed to have made the required certification in good faith.
If the loan amount is over $2m, then the loan will be subject to review by the SBA for compliance with program requirements. The borrower will need to be able to prove adequate need for the loan, or otherwise be required to pay the loan back.
For more information, see #46 in the Treasury Department’s PPP FAQs document.