SBA Proposes Major Small Business Size Standard Increases - Clark Hill

Proposed SBA Size Standard Increases: What Contractors Need to Know

October 12, 2026

By Bret S. Wacker, Ronald D. Sullivan, J. Chris White, Colleen Jarrott, and Gabrielle Long with contributions from Max Sarkissian, Law Clerk

The U.S. Small Business Administration (SBA) is proposing significant increases to the size standards used to determine eligibility for federal small-business contracting programs, which could reshape competition for set-aside contracts.

Key Takeaways:

  • The proposals would revise standards for 338 industry groups and NAICS codes, consolidating many at broader levels.
  • Some notable examples include potential increases in size thresholds for computer systems design services, administrative management consulting, advertising, and financial investment activities.

Understanding the Impact:

The competitive effects vary by industry. Contractors should carefully review the specific proposed standard applicable to their NAICS code rather than relying on SBA’s aggregate estimates.

Dividing Opinions:

  • Supporters argue that higher standards allow larger companies to compete fairly against smaller businesses that are not yet prepared for unrestricted competition in certain markets.
  • Critics maintain that some proposed thresholds are so high they would give uneasily large companies an unfair advantage over emerging contractors.

Who's Affected:

The proposal could impact:

  • Current small-business prime contractors and subcontractors
  • Contractors nearing existing size limits
  • Former small businesses seeking to regain eligibility
  • Participants in SBA socioeconomic contracting programs
  • Prime contractors with small-business subcontracting plans
  • Mentor-protégé participants and joint ventures
  • Agencies conducting market research for set-aside acquisitions
  • Investors or potential acquirers

Next Steps:

SBA has extended the comment period on the proposed standards to November 20, 2026. Contractors are encouraged to review the official proposed tables and provide feedback.

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