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From the brief of Tuesday, November 3, 2026 · No. 19

From the daily brief

SBA size-standards rewrite: comments due Nov. 20 on new limits for 338 industries

The proposal would switch many industries to a headcount test. If you bid on set-aside work or use SBA loans, check your code now.

By Carter Josephson · · 1 min read

What happened

The Small Business Administration proposed new size standards for 338 industry groups on Aug. 20, 2026 (Docket SBA-2026-0199, RIN 3245-AI67). On Sept. 24 it extended the comment deadline by 60 days, to Nov. 20, 2026.

What it means for a 10-to-50-person business

The proposal sets limits at the 4- and 5-digit NAICS level instead of the 6-digit code, and uses an employee count rather than annual receipts wherever SBA has the choice. A rule written this way can move a firm in or out of small status without any change to the firm itself. SBA's own estimate: 5,314 engineering firms (NAICS 541330) with current federal contracts would newly qualify for set-asides. SBA also says the effect on SBA 7(a) and 504 lending is minimal. Say you run a 30-person engineering or consulting practice. Small status matters if you bid on federal set-aside work, use an SBA-backed loan or want to qualify as a subcontractor to a prime that has small-business goals. If you do none of those, the effect on you is small, and you can ignore this. This is a proposal, not a final rule, so nothing changes yet.

What to do
Wait

If you do federal work or plan an SBA loan, look up your NAICS code in the proposed rule this month and file a comment by Nov. 20 if the new limit hurts you; otherwise do nothing.

What it costs
What it costs
Checking your NAICS code against the proposal, 1 owner
1 hr (≈ $75 at $75/hr)
Writing a comment, if you choose to
2 hrs (≈ $150)
Doing nothing
$0 now; you could lose or gain small status when a final rule lands, with no say in it
Sources
federalregister.gov (primary) · Comment-period extension, Federal Register

Three to five of these, every weekday morning.

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