SBA Extends Comment Period for Proposed Small Business Size Rules Overhaul
October 5, 2026
Authors: Bret S. Wacker, Ronald D. Sullivan, J. Chris White, Colleen Jarrott, Gabrielle Long (Additional contributor: Law Clerk, Max Sarkissian)
The U.S. Small Business Administration (“SBA”) has extended the public comment period for two related proposals that would significantly revise the standards used to determine small business eligibility. Comments are now due November 20, 2026.
This extension provides federal contractors, trade associations, and other stakeholders with additional time to analyze the proposed changes which impact 338 industry groups and industries. It also allows for separate comment on SBA's proposed methodology for developing these standards.
Companies should use this time to assess how the new standards would affect their eligibility, competitive position, contracting opportunities, and teaming relationships.
The Two SBA Proposals:
The extension covers two coordinated rulemaking proceedings:
Proposed Small Business Size Standards (RIN 3245-AI67; Docket No. SBA-2026-0199) - This proposal would revise size standards for 338 industry groups and industries.
Revised Size Standards Methodology (Docket No. SBA-2026-0265) - This proceeding focuses on the economic and analytical methodology SBA proposes to use when establishing, reviewing, and revising size standards.
Initially published on August 20, 2026, with a September 21, 2026 deadline, SBA granted a previous 60-day extension moving the comment period to November 20.
Why the Extension Matters:
The proposed changes could significantly impact eligibility for various federal small business programs, including:
- Small-business set-aside contracts
- 8(a) Business Development Program opportunities
- Women-Owned Small Business procurements
- Service-Disabled Veteran-Owned Small Business procurements
- HUBZone contracting opportunities
- Small-business subcontracting credit
- Certain joint ventures and mentor-protégé arrangements
The extension is crucial because the proposals involve substantial increases in size standards, broader industry groupings, and a shift from receipts-based to employee-based standards in certain sectors.
What Contractors Should Do Now:
- Identify Relevant NAICS Codes: Review codes assigned to existing contracts, contract vehicles, pending bids, material subcontractors, and pipeline opportunities.
- Compare Current vs Proposed Thresholds: Determine if your company would retain or regain small business status under the proposed standards.
- Identify Newly Eligible Competitors: Evaluate whether larger companies could qualify as small businesses under the new proposals.
- Review the Methodology: Consider whether SBA’s analysis accurately reflects market competition, concentration, operating models, and contract sizes within relevant industries.
- Prepare Data-Supported Comments: Include concrete procurement or industry evidence in your comments and propose alternatives where appropriate.