SBA Proposes Monumental Changes to Small Business Size Standards (Part 2)

As we discussed last week, on August 19, 2026, SBA proposed what can only be described as a complete shift in the paradigm of the small business size standards. In the first part of our review of these changes, we looked at the actual planned size standards themselves and how massive of a jump they represent from the norm. In that post, we also mentioned that SBA is proposing to simplify and combine several NAICS codes, as well as move several NAICS codes from receipts-based to employee-based size standards. Today, we’re going to explore this latter observation.

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SBA Proposed Rule: New Size and Status Recertification Standard

Editor’s Note: SBA implemented this rule effective January 16, 2025.

In a proposed rule in August of 2024, SBA has unveiled a brand new regulation related specifically to recertification of size and status. A frequent question of federal contractors is whether they can continue to be small, or maintain a specific socio-economic status (i.e., WOSB, SDVOSB etc.) after a change in ownership or business structure. The SBA’s size and status recertification standards are currently found in multiple places: the size determination timing regulations, each socio-economic status regulation, and of course in case law. But this would presumably create a one stop shop for size recertification questions, while also changing some of the long relied-upon standards.

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What’s on SBA’s Regulatory Plate for 2022? A Hint: Increased Size Standards

SBA publishes its semiannual Regulatory Agenda to provide an update on the various rules it has in the pipeline and an estimate for when they will be published or become final. While SBA doesn’t have to meet these timeframes, it’s always good to check in on what SBA has been working on when the final rules will come out. This agenda includes an update on increased size standards, along with some other important rules. Read on for the highlights and be sure to comment on any rules that you have an opinion on.

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