M&A Due Diligence · Cluster 2

M&A Due Diligence Checklist: 50 Items Your Attorney Should Review

Not a generic document list - a prioritized, categorized framework with red flags for each item, who reviews it, and the 10 items most commonly missed that cost buyers the most money.

By Alex Lubyansky | | 20 min read

Key Takeaways

  • 1 50 critical items across 9 categories - financial, legal, tax, operational, HR, IP/tech, environmental, commercial, and insurance.
  • 2 Each item includes a red flag indicator telling you exactly what to watch for - not just what to request.
  • 3 Every item is assigned to a reviewer - M&A attorney, CPA, buyer, or specialist - so nothing falls through the cracks.
  • 4 10 commonly overlooked items that experienced M&A attorneys catch but generalists miss - with real-world cost examples.
  • 5 Based on years of M&A practice - this is the actual framework our team uses, not a theoretical template.

Why Most Due Diligence Checklists Fail Buyers

Search for "M&A due diligence checklist" and you'll find dozens of generic document request lists. They'll tell you to collect tax returns, financial statements, and contracts. What they won't tell you is what to look for in those documents, who should review each item, or which findings actually kill deals.

This checklist is different. It's built from years of closed transactions and organized around what actually matters - with red flags, reviewer assignments, and priority ratings for every item.

How to Use This Checklist

1

Review Before LOI

Understand the scope of DD you'll need before signing the letter of intent

2

Assign Reviewers

Use the reviewer tags to delegate each section to the right professional

3

Track Red Flags

Log every finding by severity - then negotiate adjustments into the purchase agreement

Checklist Legend

ATT M&A Attorney
CPA CPA / QoE Firm
BUY Buyer
SPE Specialist
High Priority - deal-breaker risk
Medium - may adjust terms
Standard - baseline review
1

Financial Due Diligence

8 Items · Reviewer: CPA

The backbone of every deal. Validates that the business earns what the seller claims.

Quality of Earnings (QoE) Analysis CPA

Independent verification of normalized EBITDA, add-back legitimacy, and revenue sustainability.

Red flag: Add-backs exceed 30% of EBITDA or "one-time" expenses recur annually

Financial Statements (3-5 Years) CPA

Income statements, balance sheets, cash flow statements - audited if available.

Red flag: Tax returns don't match P&L statements, or revenue recognition changes year-to-year

Revenue Concentration Analysis CPA

Revenue breakdown by customer, product, geography, and channel.

Red flag: Any single customer represents >20% of revenue

Accounts Receivable / Payable Aging CPA

Current AR/AP aging schedules with collectability analysis.

Red flag: AR over 90 days exceeds 15% of total, or AP being stretched to manage cash

Working Capital Analysis CPA

Trailing 12-month working capital trends and target calculation for closing adjustment.

Red flag: Working capital declining in months leading to sale (seller draining the business)

Debt Schedule & Off-Balance-Sheet Items CPA

All outstanding debt, credit lines, guarantees, and contingent liabilities.

Red flag: Personal guarantees that won't release at closing, or undisclosed debt obligations

Capital Expenditure History & Forecast CPA

3-year capex history plus forward requirements for equipment, technology, and facilities.

Red flag: Deferred maintenance creating a capex cliff post-closing

Inventory Valuation CPA

Physical inventory count, obsolescence reserve, and FIFO/LIFO methodology.

Red flag: Obsolete or slow-moving inventory inflating asset values

2

Legal & Corporate

7 Items · Reviewer: Attorney

Identifies liabilities that survive closing and become your problems.

Material Contracts Review ATT

All customer, vendor, supplier, and service contracts - especially change-of-control provisions.

Red flag: Contracts that auto-terminate on change of ownership, or key contracts expiring within 6 months

Litigation History & Pending Claims ATT

All current, pending, and threatened litigation - plus settlements from the past 5 years.

Red flag: Active lawsuits with exposure >$100K, or pattern of employee/customer claims

Corporate Governance Documents ATT

Articles of incorporation/organization, operating agreements, shareholder agreements, cap table.

Red flag: Undisclosed shareholders, transfer restrictions, or consent requirements for the sale

Facility Leases & Real Property ATT

All lease agreements, assignment provisions, renewal terms, and landlord consent requirements.

Red flag: Lease expires within 12 months, above-market rent, or landlord consent required for assignment

Licenses, Permits & Regulatory Compliance ATT

All business licenses, professional permits, and regulatory filings - with expiration dates.

Red flag: Non-transferable licenses that require new applications, or expired permits

Related-Party Transactions ATT

Any contracts, leases, or payments between the company and its owners, officers, or their family members.

Red flag: Above-market leases to owner-related entities, or services from owner-controlled companies

Asset Ownership & Liens ATT

UCC filings, title searches, lien verification on all major assets.

Red flag: Undisclosed liens, encumbrances, or assets titled personally rather than in entity name

3

Tax Due Diligence

5 Items · Reviewer: CPA + Attorney

Tax issues don't go away at closing - they follow the business (and sometimes the buyer).

Federal & State Tax Returns (5 Years) CPA

All corporate, payroll, sales tax, and property tax returns with supporting documentation.

Red flag: Unfiled returns, amended returns, or discrepancies between returns and financial statements

Sales Tax Nexus & Compliance CPA

Sales tax registrations, filing history, and nexus analysis for all states where the business operates or sells.

Red flag: Sales tax nexus in states with no filings - exposure can be 3-7 years of back taxes plus penalties

Worker Classification Review CPA ATT

Classification of all 1099 contractors vs. W-2 employees - with IRS factor test analysis.

Red flag: Workers classified as 1099 who work exclusively for the company, use company equipment, or follow company schedules

Tax Audit History & Open Items CPA

All IRS and state audit correspondence, open assessments, and negotiated settlements.

Red flag: Pending audits, aggressive tax positions without documentation, or pattern of disputes

Deal Structure Tax Analysis CPA ATT

Tax implications of asset vs. stock purchase, Section 338(h)(10) election analysis, and allocation schedule.

Red flag: Seller insisting on stock sale without tax analysis showing benefit to buyer

4

Operational Due Diligence

6 Items · Reviewer: Buyer + Consultant

Can this business run without the current owner? This section answers that question.

Owner Dependency Assessment BUY

How involved is the owner in daily operations, key customer relationships, and sales?

Red flag: Owner manages top accounts personally, is the sole sales driver, or has no documented processes

Process Documentation & SOPs BUY

Written procedures for key operations, training materials, and organizational chart.

Red flag: Critical processes exist only in the owner's or key employee's head

Supply Chain & Vendor Dependencies BUY

Top 10 vendors, contract terms, alternative sources, and supply concentration risk.

Red flag: Single-source dependency for critical inputs with no backup supplier

Equipment & Facility Condition BUY SPE

Physical condition of facilities, equipment age, maintenance history, and replacement schedule.

Red flag: Deferred maintenance creating immediate capex needs that reduce deal value

Management Team Interviews BUY

Face-to-face meetings with key managers to assess competence, retention plans, and culture.

Red flag: Key managers uncertain about staying post-acquisition, or management team not aligned

Customer & Vendor Reference Calls BUY

Direct conversations with top 5-10 customers and key vendors about the relationship and satisfaction.

Red flag: Customers unaware of the sale, or expressing intent to RFP if ownership changes

5

HR & Employment

6 Items · Reviewer: Attorney + Buyer

People are the business. Retention, compliance, and culture make or break the transition.

Key Employee Agreements & Non-Competes ATT

Employment agreements, non-compete/non-solicitation agreements, and severance provisions for key personnel.

Red flag: Key employees with no non-competes, or change-of-control severance triggers

Employee Census & Compensation ATT CPA

Complete employee roster with titles, tenure, compensation, and benefits participation.

Red flag: Above-market compensation to owner's family members, or high turnover in key positions

Benefits Plans & Retirement Obligations ATT

Health insurance, 401(k), pension plans, PTO policies, and all benefit summaries.

Red flag: Underfunded pension obligations or accrued PTO liabilities not on the balance sheet

Employment Claims & Disputes ATT

EEOC complaints, DOL investigations, workers' comp claims, and labor disputes.

Red flag: Pattern of employment claims, pending EEOC investigations, or union organizing activity

Employee Handbook & Policies ATT

Current handbook, workplace policies, safety protocols, and compliance training records.

Red flag: No written policies, outdated handbook, or missing required workplace postings

Organizational Culture Assessment BUY

Assess company culture, management style, and how well it will integrate with your existing operations.

Red flag: Significant culture mismatches that could drive post-closing attrition

Need Help Running Due Diligence?

This checklist is our starting point. We customize every due diligence engagement based on your specific deal - industry, size, structure, and risk profile.

Request Engagement Assessment 15+ years M&A experience at competitive rates · Managing partner on every deal · Nationwide practice
6

IP & Technology

5 Items · Reviewer: Attorney + Specialist

Verify that the company actually owns the IP it claims - and that it's properly protected.

IP Ownership & Assignment Agreements ATT

Patents, trademarks, copyrights, trade secrets - plus IP assignment agreements from all employees and contractors who created them.

Red flag: IP created by contractors without written assignment agreements - they may still own it

Software Licenses & Tech Stack SPE

All software licenses (enterprise, SaaS, open-source), transferability, and compliance.

Red flag: Non-transferable licenses, open-source code in proprietary products, or end-of-life systems

Cybersecurity Posture & Breach History SPE

Security policies, breach history, penetration test results, and data privacy compliance (CCPA/GDPR).

Red flag: Prior breaches, no written security policy, or non-compliance with data privacy regulations

Domain Names & Digital Assets ATT

Domain name ownership, social media accounts, and digital asset inventory.

Red flag: Domains or social accounts registered personally rather than in entity name

IT Infrastructure & Disaster Recovery SPE

Server infrastructure, backup systems, disaster recovery plan, and business continuity procedures.

Red flag: No backup system, single-person IT management, or no disaster recovery plan

7

Environmental

4 Items · Reviewer: Specialist
Phase I Environmental Site Assessment SPE

Historical use review, site inspection, and records search for environmental contamination.

Red flag: Prior use as gas station, dry cleaner, auto shop, or industrial facility

Environmental Permits & Compliance SPE

Air, water, and waste discharge permits - current status, violations, and renewal dates.

Red flag: Expired permits, violation notices, or fines from regulatory agencies

Hazardous Materials & Waste Management SPE

Chemical inventory, storage practices, disposal records, and OSHA compliance documentation.

Red flag: Improper storage or disposal practices, or proximity to waterways or residential areas

Underground Storage Tanks & Asbestos SPE

Tank inventory, removal records, and asbestos/lead paint surveys for buildings built before 1980.

Red flag: Active or decommissioned underground tanks without proper documentation

8

Commercial & Market

5 Items · Reviewer: Buyer + Consultant
Customer Concentration & Retention Analysis BUY

Top 10 customers by revenue, contract terms, churn rate, and lifetime value trends.

Red flag: Top customer >20% of revenue, increasing churn, or at-will relationships with no contracts

Competitive Landscape & Market Position BUY

Market share, competitive threats, industry trends, and barriers to entry.

Red flag: Market shrinking or commoditizing, new well-funded competitors emerging

Sales Pipeline & Revenue Forecast BUY

Current pipeline, win rate, average deal size, and 12-month revenue forecast with assumptions.

Red flag: Inflated pipeline, declining win rates, or forecasts based on unsubstantiated assumptions

Pricing Power & Margin Sustainability BUY

Pricing history, ability to raise prices, gross margin trends, and input cost sensitivity.

Red flag: Declining margins, price-sensitive customers, or rising input costs with no pass-through

Brand & Reputation Assessment BUY

Online reviews, brand recognition, customer satisfaction metrics, and reputation risks.

Red flag: Negative online reputation, BBB complaints, or brand dependent on outgoing owner

9

Insurance

4 Items · Reviewer: Attorney + Broker
Insurance Policy Schedule ATT

All active policies - general liability, D&O, E&O, property, cyber, workers' comp, and umbrella.

Red flag: Coverage gaps in key risk areas, or policies that don't transfer to new owner

Claims History (5 Years) ATT

Loss runs from all carriers showing claims frequency, severity, and open claims.

Red flag: Frequent workers' comp claims, open product liability claims, or increasing premiums

Policy Transferability Analysis ATT

Which policies transfer to the new owner, which need new applications, and any gaps in coverage during transition.

Red flag: Key policies that terminate on change of ownership with no grace period

R&W Insurance Assessment ATT

Evaluate whether representations and warranties insurance is appropriate for the deal.

Red flag: Seller unwilling to make standard reps - R&W insurance may be necessary to bridge the gap

The 10 Most Commonly Overlooked Due Diligence Items

These are the items that experienced M&A attorneys catch but general business lawyers miss. Each one has cost buyers real money in deals we've reviewed.

1

Change-of-Control Provisions in Customer Contracts

Many customer contracts include clauses that allow termination if the business changes ownership. If your top customer's contract has this provision, you could lose 20%+ of revenue the day after closing.

Fix: Obtain customer consent as a closing condition, or restructure the deal to avoid triggering the clause.

2

Personal Goodwill vs. Enterprise Goodwill

If the business's value is tied to the owner's personal relationships, reputation, or expertise, that "personal goodwill" may not transfer. You could be paying for value that walks out the door.

Fix: Structure a consulting/transition agreement and earnout tied to customer retention metrics.

3

Sales Tax Nexus in Multiple States

If the business sells into states where it hasn't been collecting sales tax, the buyer inherits the exposure. Back taxes, penalties, and interest can accumulate to 3-7 years of uncollected tax.

Fix: Run a nexus study before closing. Address exposure through seller indemnification or purchase price reduction.

4

Worker Misclassification (1099 vs. W-2)

Workers classified as independent contractors who should be employees create payroll tax liability, benefits exposure, and potential DOL penalties. This is one of the most common middle-market findings.

Fix: Require seller remediation before closing - reclassify workers and pay back taxes.

5

IP Assignment Agreements from Employees/Contractors

Without written IP assignment agreements, employees and contractors may retain ownership of the code, designs, or content they created. The company's "core technology" might not actually belong to the company.

Fix: Require executed IP assignment agreements from all creators as a closing condition.

6

Lease Assignment Restrictions

Commercial leases often require landlord consent for assignment - and some landlords use this as an opportunity to raise rent or renegotiate terms.

Fix: Contact the landlord early in DD. Get consent terms in writing before the purchase agreement is finalized.

7

Environmental Phase I Triggers

Any deal involving real property should trigger a Phase I assessment. Prior uses (gas stations, dry cleaners, auto shops, manufacturing) can leave contamination that becomes the new owner's liability.

Fix: Always order Phase I for deals with real property. If issues found, Phase II testing before closing.

8

Insurance Policy Transferability

Many insurance policies - especially D&O and cyber - don't automatically transfer in an asset purchase. You could have a gap in coverage between closing and new policy issuance.

Fix: Engage an insurance broker 30+ days before closing to arrange new policies with no coverage gap.

9

Personal Guarantees That Don't Transfer

The seller may have personally guaranteed leases, credit lines, or vendor agreements. These guarantees don't automatically release at closing - the seller stays on the hook unless the lender/landlord explicitly releases them.

Fix: Identify all guarantees during DD and negotiate releases or replacements as closing conditions.

10

Verbal Agreements with Key Customers or Vendors

In middle-market deals, it's common to find that the biggest customer relationships are based on handshake agreements rather than written contracts. These arrangements have no legal enforceability and no transfer mechanism.

Fix: Formalize key relationships in writing before closing, or factor the risk into your valuation.

AL

Attorney Insight - Alex Lubyansky

"The 10 items above are why you need an M&A attorney, not just a business lawyer. A general practitioner will review contracts for basic terms. An experienced M&A attorney will immediately look for change-of-control provisions, personal goodwill risk, and the dozen other hidden issues that don't appear on generic checklists. It's the difference between checking boxes and actually protecting your investment."

Checklist Summary

50

Total Items

9

Categories

14

High Priority

22

Medium Priority

14

Standard

Don't Close Without Proper Due Diligence

This checklist is our starting framework. We customize every engagement to your specific deal, industry, and risk profile - so nothing slips through the cracks.

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Personal

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Frequently Asked Questions

How many items should be on an M&A due diligence checklist? +
A comprehensive due diligence checklist typically contains 100-300+ individual document requests and review items. Our 50-item checklist covers the critical categories that apply to every deal. The actual document request list your attorney creates will be customized to your specific deal - a manufacturing acquisition will have more environmental items, while a tech company acquisition will have more IP and cybersecurity items.
Who is responsible for completing the due diligence checklist? +
Due diligence is a team effort. Your M&A attorney handles legal, corporate, and contract review. Your CPA or QoE firm handles financial and tax analysis. You (the buyer) handle operational review, site visits, and management interviews. Specialized consultants handle environmental, IT/cyber, and industry-specific items as needed. Your attorney typically coordinates the overall process and manages the document request list.
How long does it take to complete M&A due diligence? +
Most middle-market due diligence periods run 60-90 days. The timeline depends on deal complexity, seller responsiveness, and the number of issues discovered. Simple deals with clean books and organized data rooms can finish in 45 days. Complex deals with regulatory approvals, multiple locations, or environmental concerns can take 120 days or more.
What's the difference between a due diligence checklist and a document request list? +
A due diligence checklist is the strategic framework - the categories and items your team needs to investigate. A document request list is the specific documents you ask the seller to provide (tax returns, contracts, employee files, etc.). Your attorney uses the checklist to create the document request list customized to your deal.
Should I use the same checklist for every deal? +
No. While the core categories apply to every deal, the specific items and depth of review should be customized based on the industry, deal size, deal structure (asset vs. stock), and risk profile. A $500K service business needs less environmental diligence than a $10M manufacturing company. Your M&A attorney will tailor the checklist to your specific transaction.
What happens when a checklist item reveals a problem? +
Each finding is categorized by severity: low (note for post-closing), medium (adjust deal terms or price), or high (potential deal-breaker). Most findings lead to purchase price adjustments, enhanced representations and warranties, seller remediation before closing, or escrow holdbacks - not deal termination. Your attorney negotiates these adjustments into the purchase agreement.
Can I do due diligence myself without an attorney? +
You can review operational items yourself - visiting facilities, interviewing management, talking to customers. But legal, financial, and tax due diligence require professional expertise. An experienced M&A attorney knows what to look for in contracts and corporate documents that a non-lawyer would miss. The cost of professional due diligence ($50K-$250K) is a fraction of the potential losses from missed issues.
What is a virtual data room and do I need one? +
A virtual data room (VDR) is a secure online platform where the seller uploads all due diligence documents for the buyer's team to review. For deals over $1M, a VDR is standard practice. Common platforms include Datasite, Intralinks, and Firmex. The seller typically sets up and pays for the VDR. A well-organized data room can accelerate due diligence by 2-4 weeks.
What are the most commonly overlooked due diligence items? +
The 10 most commonly overlooked items are: change-of-control provisions in customer contracts, personal vs. enterprise goodwill, sales tax nexus in multiple states, worker misclassification (1099 vs. W-2), IP assignment agreements from employees, lease assignment restrictions, environmental Phase I triggers, insurance policy transferability, personal guarantees that don't transfer, and verbal agreements with key customers or vendors.
How much does M&A due diligence cost? +
For middle-market deals ($1M-$50M), total due diligence costs typically range from $50,000 to $250,000. This includes legal review ($15,000-$75,000), Quality of Earnings analysis ($25,000-$100,000), and specialized consultants as needed ($10,000-$75,000). The cost generally runs 1-3% of the deal value - a small price compared to the potential losses from undiscovered problems.

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