SBA would consolidate nearly 1,000 size standards into 338; comments due 20 November
The SBA's proposed size standards overhaul would replace nearly 1,000 industry standards with 338, with comments now due 20 November 2026.
The Small Business Administration has proposed consolidating its nearly 1,000 industry size standards into 338, and the comment period on that proposal now closes on 20 November 2026. A size standard sets whether a business counts as small for federal programs, including set-asides, so a change to the standards changes who qualifies.
The proposal is not final. The current standards remain in effect until the agency issues a final rule, and the sources reviewed for this article disagree on how many firms the change would reach.
What the SBA proposed on 20 August
The SBA published two linked proposals on 20 August 2026. One would set new size standards under Docket SBA-2026-0199. The other would revise the methodology used to calculate them under Docket SBA-2026-0265. Clark Hill's notice on the extension lists both dockets and confirms that the two comment periods were extended together.
The core change is consolidation. Greenberg Traurig says the methodology would replace nearly 1,000 standards tied to six-digit NAICS codes with 338 broader ones: 276 at the four-digit industry group level and 62 at the five-digit level. CSIS puts the current number of standards at 978.
Greenberg Traurig says the methodology would also replace the current multi-factor analysis with three measures: national industry size, the number of geographic markets where firms compete, and an adjustment for net imports. According to Greenberg Traurig, the proposal would eliminate current maximum size limits and set minimums of 500 employees for employee-based standards and $30.6 million for receipts-based standards. CSIS says the current $47 million receipts ceiling and 1,500-employee ceiling would be removed.
A separate framework would make employee count the primary size measure unless Congress requires a receipts-based standard. Some receipts thresholds would see notable increases. Greenberg Traurig gives NAICS 541512 and 541519 as moving from $34 million to $531 million, and NAICS 541330 from $25.5 million to $252 million. The SBA also proposes keeping current standards unchanged in 45 industries where the methodology could produce lower figures.
How the changes could reach set-asides and federal contracts
Greenberg Traurig says the proposals would expand the pool of firms that qualify as small for set-aside procurements. Some businesses could gain eligibility, and larger firms could enter competitions that were previously limited to smaller companies. The firm also reports that the methodology would eliminate the 18 federal contracting exceptions.
The contracting figures are a subset of the 114,541 total. SBA estimates that 37,002 firms that received federal contract awards in fiscal 2025 would be newly counted as small. Those firms held approximately 105,655 contracts worth more than $71 billion, according to Greenberg Traurig's summary of the estimate.
CSIS reads the same group with more caution. Its authors say higher thresholds could reduce the growth penalty for successful contractors, but firms that graduate from small status can lose access to set-aside competitions. They also warn that adding roughly 37,000 established contractors could make it harder for smaller firms to compete for those contracts.
The sources reviewed do not address size protests, and none describes how existing contract awards would be treated under the new standards.
What the sources say about SBA loans
The pages reviewed for this article describe loan effects only in general terms. CSIS says small-business status affects SBA-backed financing and other federal programs. It does not name the 7(a) or 504 programs or set out loan-specific thresholds. The Greenberg Traurig summary does not address SBA loan programs at all.
Until the final rule is published, the current standards govern eligibility. The proposed rules themselves are the place to check any loan-related effects, which the sources reviewed do not describe.
“The proposals would replace nearly 1,000 size standards with 338, and the current standards stay in force until a final rule is issued.”
Where the firm-count estimates disagree
Greenberg Traurig reports that SBA estimates approximately 114,541 firms would be newly classified as small. CSIS cites an estimated 114,000 existing midsize firms and gives a total of about 6.41 million small businesses after the change, an increase of 1.8 percent from about 6.3 million. Those figures are consistent with the 114,541 figure once rounding is allowed for: 1.8 percent of about 6.3 million is about 113,000.
The largest gap concerns the contracting estimate. Washington Technology reports that the Office of Advocacy released a revised estimate on 27 September saying only 4,000 to 6,000 current contractors would qualify as small under the proposal. SBA's earlier figure was about 115,000 additional companies. The same article says the SBA memo extending the deadline does not mention the Advocacy report. That memo cites requests for more time and SBA's clarification of the proposal's impacts.
Only one source in this review reports the Advocacy estimate, so it should be read as a reported figure rather than one confirmed across the record.
What to check before 20 November
Clark Hill's notice recommends that businesses first identify the NAICS codes that apply to them, then compare current and proposed thresholds for each code. It also recommends preparing comments supported by data, and it cautions companies against changing their size representations or certifications based solely on the proposed standards.
Confirm the dates first. The original deadline was 21 September 2026, and the extension moves it to 20 November. Washington Technology reported that Regulations.gov still listed both proposals as closed when the extension was announced, and that the extension memo was due in the Federal Register later that week. Confirm that the dockets accept comments before filing.
Companies that hold or pursue federal contracts should track set-aside solicitations and the NAICS codes attached to them, because, as CSIS notes, size thresholds depend on NAICS category along with employment and revenue. Companies with SBA loans or applications should read the proposed rules directly, since the summaries reviewed here do not describe loan effects.
