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Big Is Now Small?

By Reggie Jones & Jacob Green on September 3, 2026
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Table of Contents

  • The Big Picture
  • Key Changes that Matter for Contractors
  • What the New Standards Look Like in Practice
  • Key Takeaways

The Small Business Administration (SBA) announced a new proposed rule on August 20, 2026 that will overhaul how it defines small businesses.[1] If finalized, the rule would be one of the most significant changes to size standards in over a decade—and government contractors should pay close attention because, if finalized, these changes will likely have a huge disruptive effect.  While the size standards have long needed reasonable upward adjustment to help small business concerns grow large enough to survive graduation out of the program, these changes would effectively pit large, established, institutional contractors against true emerging small businesses.     

Link to The Big Picture The Big Picture

The SBA is simplifying how it determines whether your company qualifies as a “small business” for federal contracting purposes. The proposed rule consolidates nearly 1,000 size standards at the 6-digit NAICS code level into just 338 standards at the 4- and 5-digit NAICS level. It also eliminates all size standard “exceptions,” which have long been a source of confusion for contractors trying to determine the right standard for their work.

This means that thousands of large businesses would be newly classified as small under the proposed standards and eligible to compete for set-aside contract awards.

Link to Key Changes that Matter for Contractors Key Changes that Matter for Contractors

Shift from receipts to employees. Many industries currently measured by average annual receipts would switch to employee-based size standards. This is significant because employee-based standards are less volatile so your small business status will no longer swing based on a single high-revenue year or inflationary pressures.

Higher ceilings, more room to grow. The revised methodology removes the previous maximum cap on size standards and adds a first-ever productivity adjustment for monetary-based standards. For contractors who have been reluctant to pursue growth opportunities out of fear of exceeding their size standard (the so-called “benefit cliff”) this rule pushes that cliff further out.

More competition for set-asides. The SBA estimates that roughly 37,002 firms with existing federal contracts will become newly eligible small businesses. Those firms accounted for over $71 billion in FY 2025 contract dollars. If you are an incumbent small business, expect increased competition for set-aside contracts, particularly from mid-size firms that were previously too large to qualify.

Expanded access to SBA loans. Small business status also opens the door to SBA lending programs, including the 7(a) and 504 loan programs. In FY 2026 alone, $23 billion was approved for over 43,000 loans under the 7(a) program and $5.5 billion for the 504 program. Newly qualified businesses will also be eligible for Economic Injury Disaster Loans (EIDLs) and the recently introduced 7(a) Working Capital Pilot Program, which has already delivered more than $150 million in new lending since its inception. For firms that previously exceeded the size threshold, this represents a significant new avenue for financing growth, equipment, and workforce development.

Link to What the New Standards Look Like in Practice What the New Standards Look Like in Practice

Former NAICSFormer Size StandardNew NAICSNew Size Standard
236220 Building Construction$45M23713 Construction1500 Employees
486210 Pipeline Transportation of Natural Gas$41.5M4862 Pipeline Transportation of Natural Gas$477M
541310 Architectural Services$12.5M54131 Architectural Services$135M
541330 Engineering Services$25.5M54133 Engineering Services$252M
541512 Computer Systems Design Services$34M5415 Computer Systems Design and Related Services$531M
541611 Administrative Management and General Management Consulting Services$24.5M5416 Management, Scientific, and Technical Consulting Services$295M
813910 Business Associations$15.5M8139  Business, Professional, Labor, Political, and Similar Organizations$632M

Link to Key Takeaways Key Takeaways

Proposed, not final. While this new SBA proposal is a massive departure from previous standards, this is still only a proposed rule. The size standards currently in effect remain unchanged until the SBA finalizes this rulemaking. If you are looking to comment on the proposal, make sure to submit your feedback by the September 21, 2026 deadline. 

Confirm your size status. Review the proposed size standard for your NAICS code and determine whether your company would be classified differently under the new framework. That might include new calculations if your status has switched from receipts to employee based. 

Look for new opportunities. If the proposed rule would make your firm newly eligible as a small business, start identifying set-aside contracts or SBA loan programs that might align with your business goals.


[1] The SBA also posted the methodology behind its new proposal here.

  • Posted in:
    Administrative and Regulatory, Government Contracts
  • Blog:
    The Federal Government Contracts & Procurement Blog
  • Organization:
    Fox Rothschild LLP
  • Article: View Original Source

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