SBA Proposed Size Standards 2026: What GSA Schedule Holders Should Do Now

SBA has proposed replacing nearly 1,000 small business size standards with 338 broader ones and raising most of them sharply: IT services in NAICS 5415 would jump from $34 million to $531 million in receipts. Nothing changes yet. Comments are now due November 20, 2026, and current standards stay in force until a final rule is published.

I spent eighteen years in federal acquisition as a Contracting Specialist and Contracting Officer at GSA, IRS, DoD, DOI, HHS, FTC, and Energy. This is the biggest size-standard proposal I have seen, and GSA Multiple Award Schedule (MAS) holders are the most likely to misread it.

What exactly did SBA propose in August 2026?

On August 20, 2026, SBA published two linked documents: a proposed rule rewriting the size standards table at 13 CFR 121.201 (91 FR 53741, Docket SBA-2026-0199, RIN 3245-AI67) and a revised size standards methodology (91 FR 54096, Docket SBA-2026-0265). Together they consolidate, raise, and restructure nearly every size standard.

• Consolidation: 978 six-digit industry standards plus 18 exceptions collapse into 338 standards, with 276 set at the 4-digit NAICS level and 62 at the 5-digit level.
• Exceptions eliminated: SBA proposes to end all 18 size standard exceptions used for federal contracting.
• No reductions: SBA's model recommended lower standards in 45 industries, but SBA proposes not to reduce any of them.
• New floor and no ceiling: the minimum receipts-based standard becomes $30.6 million (rounded to $31 million in the table), the minimum employee-based standard is 500 employees, and the old caps of $47 million and 1,500 employees disappear.
• Productivity adjustment: for the first time, receipts-based standards would be adjusted for productivity growth on top of inflation.
• Measure changes: many industries move from receipts-based to employee-based standards.

Read the proposed rule and the revised methodology yourself.

When is the comment deadline, and when would the new standards take effect?

The comment deadline is November 20, 2026. SBA originally set September 21, 2026, then extended both comment periods by 60 days in a notice published September 24, 2026 (91 FR 60524). No effective date has been set. The current size standards remain in effect until SBA publishes a final rule.

Do not change your SAM.gov size representations based on a proposed rule. Until a final rule publishes, represent under the current 13 CFR 121.201 table.

How much would size standards rise for common GSA Schedule NAICS codes?

For the professional services and IT codes that dominate MAS, the increases run roughly threefold to more than fifteenfold. Engineering services rise from $25.5 million to $252 million, management consulting from $24.5 million to $295 million, and custom programming from $34 million to $531 million.

These figures come from SBA's comparison table in the proposed rule (91 FR 53761 to 53764):

Notice the last row. Software publishing switches from a receipts test to an employee test, which changes the math, not just the number.

Who gains small business status under the proposal?

Mid-sized firms that outgrew the current standards gain the most. SBA's rule estimates 114,541 firms would become newly small, including 37,002 firms that held roughly 105,655 federal contracts worth about $71 billion in FY 2025. SBA's Office of Advocacy later estimated 4,000 to 6,000 current contractors would gain status.

The September Office of Advocacy statement measured the effect on the federal small business contracting marketplace, against roughly 56,000 firms currently participating. Either way, the firms regaining status cluster where GSA sells. Per the rule's own table:

• Engineering services (541330): 5,314 firms with current contracts become small.
• Other computer related services (541519): 2,247 firms.
• Custom computer programming (541511): 2,171 firms.
• Management consulting (541611): 1,818 firms.
• Computer systems design (541512): 1,663 firms.

If you graduated out of small status recently, this proposal could put you back into set-aside competition.

Which small contractors could lose small status or lose ground?

Very few firms lose status on paper, because SBA proposes no reductions. The real exposure is competitive: firms under $25 million that stay small but now face competitors ten times their size on the same set-aside. A narrower group, firms in industries switching from receipts to employees, must recheck eligibility under the new measure.

1. Industries changing measure. A labor-heavy firm with modest receipts can pass a receipts test and fail an employee test. SBA itself acknowledges one industry where the change in measure effectively lowers the standard.
2. Firms relying on an exception. All 18 exceptions go away. If your eligibility depends on an exception rather than the base NAICS standard, compare your numbers to the new consolidated standard.
3. Small firms in newly crowded codes. A $6 million consulting firm stays small under 541611. So does a $250 million firm. They would compete for the same set-aside BPA call or MAS order.
4. Subcontractors to reclassified primes. Small business prime awards do not carry subcontracting plan requirements under FAR 19.702, so fewer large-prime awards can mean fewer plan-driven subcontracts.

When I sat on the Contracting Officer side of a set-aside order, my market research question was simple: can I find two or more capable small businesses? Under these standards that answer becomes yes far more often, including on larger, consolidated requirements. That is a harder market for the $3 million shop building past performance.

How is size determined for GSA MAS orders today?

For MAS, size is locked to your initial MAS offer. Under 13 CFR 121.404(c)(4)(i), size for MAS orders and BPAs is determined as of the date you submitted your initial offer, including price, for the MAS contract, unless a Contracting Officer requests recertification for a specific set-aside order under 13 CFR 125.12(c).

• Order-level recertification: if an ordering CO asks you to recertify on a specific order and you are no longer small, you are ineligible only for that order. You stay eligible for others where no recertification is requested (13 CFR 121.404).
• Long-term recertification: for contracts over five years, which includes every MAS contract, you must recertify size no more than 120 days before the end of year five and before each option thereafter (13 CFR 125.12(b)).
• Mergers and acquisitions: recertification is required within 30 days of a merger, acquisition, or sale that changes controlling interest (13 CFR 125.12(a)).
• The clause: FAR 52.219-28, Post-Award Small Business Program Rerepresentation, is how these events flow into your contract, and FAR subpart 19.1 points back to SBA's table for the standards themselves.

As a Contracting Specialist, I watched option mods stall over stale size rerepresentations more often than over pricing. Contractors treat it as a formality. It sets your size status for the next five years.

What happens at your next MAS option if the rule becomes final?

Your next rerepresentation would be measured against the new standard. Under 13 CFR 125.12(a)(4), a recertification relates to the size standard in effect at the time of recertification for the NAICS code originally assigned. A MAS holder that recertified as other than small could recertify as small at the next option.

Across our 70+ GSA contract awards, the firms that handled size transitions cleanly kept a running size calculation updated every fiscal year. Start that file now.

What should you do now?

Run your numbers under both tables, comment by November 20, 2026, and keep representing under current standards until a final rule publishes. MAS holders should also map each SIN's NAICS code to its proposed standard and calendar their next 125.12 recertification date.

• Pull your NAICS list from SAM.gov and your MAS SINs, then find each code's proposed standard in the rule's table.
• Recalculate size both ways: average annual receipts under the current standard, and average employees if your code is switching measures.
• Calendar your option date and the 120-day recertification window before it.
• Submit a specific comment through the regulations.gov docket SBA-2026-0199. Revenue range, NAICS codes, set-aside dependence, and named competitor sizes carry more weight than general objections.
• Revisit teaming plans. Reclassified partners may decide they no longer need a small teammate.

If you hold a GSA Schedule and want a second set of eyes on your size position, option timing, and rerepresentation before the next mod lands, that is exactly what our GSA Schedule maintenance program covers, from a former Contracting Officer who has processed these actions from the government side.

Frequently Asked Questions

What is the deadline to comment on SBA's proposed size standards?

Comments are due November 20, 2026. SBA extended the original September 21, 2026 deadline by 60 days in a notice published September 24, 2026 (91 FR 60524). You can comment on the proposed rule under docket SBA-2026-0199 and on the methodology under docket SBA-2026-0265 at regulations.gov.

Are the new SBA size standards in effect now?

No. They are proposed only, and SBA has not set an effective date. Current size standards in 13 CFR 121.201 remain in effect, so your SAM.gov representations should follow the existing table until a final rule is published.

What would the size standard be for IT services under the proposal?

SBA proposes $531 million in average annual receipts for NAICS 541511, 541512, and 541519, up from $34 million today. NAICS 518210 would rise from $40 million to $402 million.

Will any contractor lose small business status under the proposed rule?

SBA proposes not to reduce any size standard, so few firms lose status on paper. Firms in industries switching from a receipts test to an employee test, or firms that relied on one of the 18 exceptions being eliminated, should recalculate their size under the new measure.

How is small business size determined for GSA Schedule orders?

Under 13 CFR 121.404(c)(4)(i), size for MAS orders and BPAs is determined as of your initial offer on the MAS contract. A Contracting Officer can request recertification for a specific set-aside order, and if you are no longer small you are ineligible only for that order.

When must a GSA MAS contractor rerepresent its size?

Under 13 CFR 125.12, you must recertify within 30 days of a merger, acquisition, or sale that changes controlling interest, and no more than 120 days before the end of year five and before each option thereafter. FAR 52.219-28 implements these rerepresentation requirements in your contract.

Could a GSA contractor that is no longer small become small again?

Yes, if the rule is finalized as proposed. Under 13 CFR 125.12(a)(4), a recertification is measured against the size standard in effect at the time of recertification for the NAICS code originally assigned, so a higher standard could allow a qualifying recertification at the next option.