The SBA Size Standards Overhaul 2026 Isn’t the Only Rule Still Pending
The SBA size standards overhaul 2026 proposal, published August 20, 2026, would replace nearly 1,000 industry-specific standards with 338 broader groupings. Some thresholds rise more than tenfold. It is not the only size-standard rule SBA has pending. A separate proposal from August 2025 covers 263 industries, and a year later, as of August 31, 2026, it still isn’t final. A founder, BD lead, or capture lead at a mid-market firm checking set-aside eligibility now has two unfinished rules to track, not one. Mix them up and you can chase a set-aside you don’t yet qualify for.
| Field | Answer |
|---|---|
| Signal | SBA proposed new size standards for 338 industry groups on Aug. 20, 2026, while a separate 2025 proposal covering 263 industries remains unfinalized |
| BD implication | Neither rule is in effect; a firm assuming a higher threshold already applies risks pursuing a set-aside under the wrong standard |
| Customer | N/A, this is an eligibility rule, not a procurement action |
| Buyer | N/A, no specific federal buyer or contract vehicle is implicated by either rule |
| Funding | N/A, an eligibility-classification change, not appropriated or obligated spend |
| Vehicle / path | N/A, the rules change eligibility criteria that apply across existing small-business set-aside vehicles government-wide, once finalized |
| Incumbents / ecosystem | N/A, no specific companies are named; the affected population is the full set of firms near their current size threshold |
| Access strategy | Check your own NAICS classification against the new proposal, and comment before Sept. 21, 2026 if it affects you |
| Timing | New proposal’s comment period runs through Sept. 21, 2026; the 2025 proposal’s comment period closed Oct. 21, 2025 with no final rule since |
| Confidence | Medium |
| Pursuit posture | WATCH, with a dated near-term action (the comment deadline) |
| Upgrade triggers | Either rule is finalized, or SBA states how the two relate |
| Downgrade triggers | Both proposals are withdrawn or indefinitely tabled with no successor action |
- The 2026 proposal consolidates nearly 1,000 industry standards into 338 groups and expands who qualifies as small.
- The 2025 proposal, covering 263 industries, closed its comment period in October 2025 and remains unfinalized as of August 31, 2026.
- The two proposals carry distinct RINs and distinct dockets.
Why a Reader Would Assume This Already Happened
The confusion is fair. Two rules on the same subject, announced a year apart, both still pending, read as one ongoing update. But each has its own docket and its own comment period. Tracking them as one risks acting on a threshold that isn’t yours to use yet.
What the SBA Size Standards Overhaul 2026 Restructures
SBA’s new proposal would change how it sets standards, not just where the numbers land. Industry grouping would shift from today’s six-digit NAICS codes to four-digit categories, and a new “market-size approach” would weigh regional competition alongside national industry size. Nearly 1,000 separate standards would collapse into 338 broader groupings if the rule finalizes.
Some jumps are steep. Custom computer programming services would move from a $34 million receipts standard to roughly $531 million. Engineering services would rise from about $25.5 million to roughly $252 million. On the employee side, semiconductor manufacturing would go from 1,250 to 2,800 employees, shipbuilding from 1,300 to 2,300, and oil and gas drilling from 1,000 to 2,650.
This proposal carries the formal designation RIN 3245-AI67, distinct from RIN 3245-AI12 on the 2025 proposal. It reportedly splits the 338 standards into 208 employee-based, 129 receipts-based, and one asset-based. SBA reportedly proposes no reduction to any standard, even where its own analysis is said to have supported one.
For a firm in a converting industry, the change is a different eligibility test, not just a different number. Construction is one industry reportedly converting from receipts-based to employee-based measurement. A construction firm measured against a receipts ceiling today would check an employee count instead, once a final rule takes effect. The two metrics don’t track each other, so a firm can clear one test and fail the other. Check which metric your own industry uses under the proposal before you trust your current receipts figure.
The 2025 Proposal Is a Separate, Still-Unfinished Rule
This isn’t SBA’s first size-standard rewrite this cycle. In August 2025, SBA proposed a separate rule on monetary-based standards in 263 industries: 259 receipts-based and four asset-based. That rule’s comment period closed October 21, 2025. SBA has announced no final rule as of August 31, 2026. A rule this wide usually goes through a long interagency review first. That review can push a final rule well past its comment-period close. SBA hasn’t stated a reason for this delay.
- August 2025: SBA proposes monetary-based size-standard increases across 263 industries.
- October 2025: Comment period on that proposal closes.
- August 2026: With the 2025 proposal still unfinalized, SBA proposes a second, much larger rewrite covering nearly 1,000 industries, restructured into 338 groups under a new methodology.
- September 2026: Comment deadline for the new proposal.
- Ongoing: Neither rule has been finalized as of August 31, 2026.
| Rule | RIN | Industries covered | Comment period | Status as of Aug. 31, 2026 |
|---|---|---|---|---|
| 2025 monetary-based proposal | 3245-AI12 | 263 | Closed Oct. 21, 2025 | No final rule announced |
| 2026 restructuring proposal | 3245-AI67 | ~1,000, consolidated to 338 | Open through Sept. 21, 2026 | No final rule announced |
The two proposals differ in more than scope:
- The 2025 proposal only adjusts monetary thresholds; the 2026 proposal also converts some industries, construction among them, from receipts-based to employee-based measurement entirely.
- The 2025 proposal keeps six-digit NAICS codes; the 2026 proposal collapses them into 338 broader four- and five-digit groupings.
- The 2026 proposal reportedly declines to lower any standard, even where SBA’s own analysis is said to have supported a decrease; the 2025 proposal makes no comparable statement.
The 2026 proposal may supersede the 2025 one, withdraw it, or run alongside it. SBA has made no public statement on how the two relate. When a set-aside decision rides on either rule, don’t assume one supersedes the other until SBA says so.
What This Means If You’re Near Your Size Threshold
Neither proposal sets the standard you’re measured against today. That standard predates both. Confirming which standard still applies to your NAICS code matters most in two cases. In the first, the proposed standard for your industry would flip your status. In the second, your industry is converting from receipts-based to employee-based measurement, the way construction is reported to be. That conversion changes which number you check, not just how large it is.
A higher threshold in the new proposal is not yours to claim yet. Confirm the standard in force before you pursue a set-aside built on a proposed number.
- Comment before September 21, 2026 if you want to influence where your own industry’s line gets drawn.
- That window closes before any final rule locks the number in.
- SBA must review and respond to substantive comments before it finalizes a rule, so a comment tied to your own NAICS code and the dollar or employee figure at stake for your industry carries more weight than a general objection.
How Tracking Two Rules at Once Works
The two dockets differ in scope, and they run on different clocks. The 2025 proposal’s comment window closed nearly a year ago. The 2026 proposal’s stays open through September 21, 2026. A firm that treats them as one bucket can miss the docket where a comment still changes the outcome.
- Identify your current NAICS code and confirm the size standard in force for it today, not the proposed one.
- Check whether your NAICS code falls under the 2025 proposal, the 2026 proposal, or both, since the two cover different scopes.
- Note which comment window is still open for your industry, since only the 2026 proposal’s remains active.
- Track both dockets by their own RIN, and watch for a final rule or an explicit SBA statement on how the two relate.
Why This Isn’t a Simple Continuation of Last Year’s Story
The SBA size standards overhaul 2026 covers nearly four times the industry count of the 2025 proposal. That scale is the strongest argument against reading it as a continuation of last year’s story. For a founder or BD lead, the near-term action is narrow. Don’t act on either proposed threshold as if it’s already in force. If the 2026 proposal touches your industry, the comment window is a dated chance to weigh in before the number is set. Next comes a final rule under either RIN, or a statement on how the two relate.
FAQ
Could a size protest turn on which standard was in force when a solicitation issued?
Yes, in principle. A size determination usually applies the standard in effect on the date a solicitation is issued, not a standard proposed afterward. A firm that pursues a set-aside under a still-proposed threshold invites a protest. A competitor can challenge its size status against the standard in force that day.
What happens to a size recertification if a firm becomes newly small after either rule finalizes?
Recertification runs on its own triggers, separate from either proposed rule. Common triggers include contract renewal, a merger or acquisition, or a long-term contract’s five-year mark. A firm that becomes newly small doesn’t gain set-aside status on an existing contract by default. It has to hit one of those triggers first.
Does a new size standard apply the same day at every contracting office?
Yes. A final size-standard rule takes effect government-wide on one date, not office by office. Each solicitation applies the standard in force on its own issuance date. What matters is the rule’s effective date, not when any one office updates its guidance.
If your firm would only qualify as small under the 2026 proposal, what should you do before it’s final?
Treat the eligibility as a plan, not a current fact. Confirm the proposed status of your NAICS code. Prepare the documentation you’d need if the rule finalizes as written. Hold off on any set-aside pursuit that depends on it until SBA issues a final rule.
Is the 110,000-plus newly-eligible-firms figure real spending, or a threshold change?
Over 110,000 firms would join the small business pool if the 2026 proposal finalizes as written. That’s a threshold change, not new federal spending. It sets who can compete for set-asides, not how much money is appropriated for them.
Does the 2025 proposal being unfinalized after a year mean it will never be finalized?
Not necessarily. A rulemaking of this size can sit in interagency review for a long time without being abandoned. A withdrawal notice would signal it’s dead, and so would an SBA statement that it is folding the rule into the 2026 proposal. Continued silence doesn’t.
