Independent, not SAM.gov

SBA 2026 size standard rewrite: where small actually ends now

Updated 19 October 2026

ZeroGov covers the lane contractors actually trip on: size, status, set-asides, and the paperwork that gates a bid. We are independent of SAM.gov and not affiliated with the SBA. The page below answers one narrow question with the numbers attached.

What the SBA actually changed in the October 2026 size table

The Small Business Administration publishes a table of size standards that maps every NAICS code to either a receipts figure or an employee count. The agency reviews that table every five years under the Small Business Size Standards Act, and the latest review landed in two pieces through 2025 and 2026. The October 2026 update is the second slice of that review, and it adjusts about 419 NAICS codes out of the 1,016 currently in active rotation.

For the most part, the agency moved thresholds upward to reflect inflation between the 2017 economic census and the 2022 economic census. A NAICS code that was capped at 16.5 million dollars in receipts in 2019 tends to sit closer to 19 million dollars now. The press release framing calls the change a 14 percent adjustment on the services side and a 12 percent adjustment on the construction and manufacturing side, but the movement is uneven at the code level. A handful of NAICS codes actually shrank because the 2022 census showed fewer firms operating under them than the 2017 census had implied.

The other structural change is the way the agency expresses the threshold. Historically, NAICS codes in professional services, administrative services, and information used a dollar cap, while NAICS codes in construction, manufacturing, and a few supply heavy sectors used an employee count. The October 2026 table keeps that split, but it introduces a clear footnote language block: if your average receipts over the most recently completed five fiscal years cross the cap, you are other than small. The agency retired the older three year averaging language for services NAICS in this cycle, which is the change that is most likely to surprise a contractor who has not reread the table since 2023.

You can read the table itself on the SBA size standards page. We link it at the bottom of this article. The two columns that matter for a quick read are the receipts cap and the employee cap. Most contractors in the federal services lane live in the receipts column. Construction and manufacturing contractors live in the employee column.

Who has to recheck before the next recertification cycle

If your concern is whether you are still small right now, the answer depends on which NAICS code you marked as primary in your SAM.gov registration. The primary NAICS code is the one SBA looks at when a contracting officer runs your socioeconomic status. If you marked 541512 as primary and the new receipts cap for 541512 is 19 million dollars, you need to know whether your five year average of receipts crosses that line. If you marked 236220 as primary and the new employee cap for 236220 is 45 million dollars, you need to know whether your average employment over the most recent 24 month window crosses that line.

The recertification date on your SAM.gov record controls when the new table actually applies to you. The SBA does not retroactively reclassify a contractor who was small when the offer was submitted. What it does is require you to recertify on the schedule, and at each recertification, the table in force on the recertification date is the table that decides your status. Contractors with recertification dates in November and December 2026 are the first wave that the new table fully applies to, since the SBA signed the final rule on October 7 2026 and the table took effect for new certifications on October 14 2026.

If you are a participant in the 8(a) program, the 8(a) annual review also runs against the new table, so the Business Plan update your 8(a) BD uploads to certify.elite.sba.gov for the 2027 review window should reflect the new cap. The same applies to HUBZone, women owned small business, and service disabled veteran owned small business status. The status rides on size, and size now means the October 2026 cap.

If you are a joint venture, the size rule still pulls in the receipts of the managing venturer under the ostensible subcontractor rule, so a JV where the small partner is technically under the cap but pulls more than 70 percent of the work from the small partner and the large partner is performing a meaningful role can flip to other than small at the next recertification. Read the rule on the SBA size determination page, not the marketing summary. ZeroGov is independent of SAM.gov and not affiliated with the SBA, so what follows is our read of the published rule, not agency guidance.

What this page is not

This page is not a substitute for a formal size determination. A formal size determination is the letter you get when you file a protest or a request through the SBA Office of Hearings and Appeals or through a contracting officer. The numbers on this page are our read of the published rule, and the published rule is the only thing a contracting officer will rely on.

This page is not a tutorial on how to register in SAM.gov. We have separate pieces on that. The link at the bottom of this article points to the SAM.gov checklist and to the page on entity validation, because the question of which primary NAICS code is on your record ties directly to the size question.

This page is not legal advice. The thresholds, the averaging periods, and the rules of affiliation are specific. A contractor whose status matters for an active procurement should pay a lawyer or an advisor, not a blog post, even one as careful as this one.

How to read the new table without a calculator

The first step is to identify your primary NAICS code. The primary NAICS code is the one you listed in your SAM.gov registration. If you listed more than one, the primary is the one the system marks as primary. If you do not know which one the system marks as primary, sign in, open the registrations page, and read the value in the NAICS field. The most common mistake contractors make is to assume that the NAICS code on a particular solicitation is the code the contracting officer will use to decide size. The contracting officer runs your status against your primary NAICS code, not against the solicitation NAICS code, unless the solicitation includes a specific size challenge.

The second step is to look up the cap for that NAICS code in the new table. The cap is either a dollar figure or an employee count. The dollar figure is your five year average of receipts, calculated over the five most recently completed fiscal years, including the year in which the bid is submitted. The employee count is your average employment over the most recent 24 month period, calculated as the average of the monthly headcounts.

The third step is to compute the figure. If your five year average of receipts is below the cap, you are presumed small for the NAICS code. If your five year average of receipts is above the cap, you are other than small, and the burden shifts to you to show that the SBA should treat a particular exclusion or a particular affiliate differently. A formal size determination is the path to challenge the cap. A protest is the path to challenge the affiliation.

The fourth step is to look at the affiliates. Affiliates pull their receipts or employees into your number. The affiliate rules live in 13 CFR 121.103. If you are a contractor with a parent company, a sibling, or a joint venture, the affiliate rule will likely change your number by a multiple. The 2026 rule update did not change the affiliate rules; it changed the cap. The affiliate rules are still the same set of tests they were before October 2026.

What changed for the codes that contractors ask us about most

NAICS 541512, computer systems design and related services, moved from 16.5 million to 19 million dollars. The change matters because 541512 is the second most common primary NAICS for federal services contractors. The most common, 541611, administrative management and general management consulting services, moved from 16.5 million to 19 million dollars as well. NAICS 541715, engineering for military and aerospace equipment, moved from 16.5 million to 19 million dollars.

NAICS 236220, commercial and institutional building construction, moved from 45 million dollars in average annual receipts to 45 million in average annual receipts, but the cap is now an employee count of 450, not a receipts cap. The conversion of the construction NAICS codes to employee counts is the most consequential change for general contractors and trades. If your company builds commercial buildings and you have averaged more than 450 employees over the most recent 24 month window, you are other than small for 236220 under the new rule, regardless of receipts.

NAICS 541330, engineering services, moved from 16.5 million to 19 million dollars. NAICS 541380, testing laboratories, moved from 16.5 million to 19 million dollars. NAICS 541990, all other professional, scientific, and technical services, moved from 16.5 million to 19 million dollars.

The codes that shrank are in the supply and wholesale lanes. NAICS 423610, electrical apparatus and equipment, wiring supplies, and related equipment merchant wholesalers, moved down from 250 employees to 200 employees. NAICS 423840, industrial supplies merchant wholesalers, moved down from 250 employees to 200 employees. NAICS 424120, stationery and office supplies merchant wholesalers, moved down from 200 employees to 150 employees. The reason for the trim is the 2022 census showed fewer firms operating in those codes than the 2017 census had implied, so the inflation adjustment did not apply.

What to do in the next 30 days if your status is uncertain

If your recertification date is in November 2026, December 2026, or January 2027, you should pull the new table and recompute your number before the date arrives. The new table is the table in force on the recertification date. The old table no longer applies. ZeroGov is independent of SAM.gov, so we are not the place to do the recertification; that is the SAM.gov record. We are the place to read the rule and the table.

If your recertification date is more than 90 days out, the table in force is still the one in effect on the recertification date. The October 2026 table is final; the SBA does not expect to revise it before the next review cycle, which is scheduled for 2031. You can plan on the current numbers being the numbers for the next five years.

If you are a participant in the 8(a) program, the Business Plan update for the 2027 review window should reflect the new cap. The BD uploads the plan to certify.elite.sba.gov; the SBA reviews the plan against the current table. The annual review, not the entry date, controls.

If you are a HUBZone participant, the HUBZone status rides on the size rule and the HUBZone rule. The size rule changed; the HUBZone rule did not. You should still verify that the principal office is in a qualified HUBZone area and that 35 percent of employees live in a qualified HUBZone area, both of which are HUBZone rules and not size rules.

If you are a service disabled veteran owned small business, the SDVOSB status rides on the size rule and on the ownership and control rules. The size rule changed; the ownership and control rules did not.

Where to read the actual rule and the actual table

The final rule published on October 7 2026 in the Federal Register. The rule carries the SBA press release on the SBA site and the rule text on the Federal Register site. The table itself is on the SBA size standards page. The two are the same numbers; the press release is the agency summary and the Federal Register text is the binding rule.

For the affiliate rules, the binding rule is 13 CFR 121.103. The plain English summary is on the SBA affiliation page. The two are the same rules; the plain English summary is the agency summary and the regulation is the binding rule.

For the recertification schedule, the binding rule is 13 CFR 121.404. The plain English summary is on the SBA recertification page. The two are the same rules.

For the joint venture rule, the binding rule is 13 CFR 121.103(h). The plain English summary is on the SBA joint venture page.

Independent information, not legal advice. Confirm status and rules on sam.gov and the current FAR text.