SBA's Revised Size Standards Methodology Cuts Seven Factors Down to Three

What changed

Alongside its proposed size standards rule, SBA published a notice of availability on 20 August 2026 releasing the 2026 Revised Size Standards Methodology white paper for comment (91 FR 54096, Docket No. SBA-2026-0265). Comments were originally due 21 September 2026 and are now due 20 November 2026 (see the update below). The Revised Methodology is the analytical basis for the numbers in the companion proposed rule, and SBA incorporates it by reference into that rulemaking.

The 2024 Methodology calculated a size standard from seven factors: simple average firm size, weighted average firm size, average assets per firm, the national four-firm concentration ratio, the national Gini coefficient, and two federal contracting disparity ratios applied to industries averaging at least $20 million in annual federal contract dollars. Each factor produced its own candidate standard, and the results were averaged.

The Revised Methodology uses three: national industry size, the number of distinct geographic markets in which competition takes place, and an adjustment for imports and exports. Those combine into a single average market size measure, which a single function converts into a size standard. SBA also removes the explicit maximum size standard while retaining a minimum, and adds a productivity adjustment to monetary standards on top of the inflation adjustment. SBA grounds the shift in the statutory phrase "not dominant in its field of operations" at 15 U.S.C. 632, reading "field of operations" to include a geographic dimension, and cites the Horizontal Merger Guidelines approach to market definition as the analogue.

Why it matters

The proposed table of standards is the current answer. The methodology is the machine that will generate the next several answers, including the next five-year review under the Small Business Jobs Act. Two structural choices carry forward. Removing the maximum lets standards rise further than the old comparison-group range allowed, so industries that were previously capped can move substantially. Adding a productivity adjustment means monetary standards drift upward faster than inflation alone, compounding between reviews.

There is also a practical point for anyone who comments. Objecting to a specific threshold without engaging the methodology addresses the output, not the calculation that produced it. The two dockets are separate, so a comment on the standard for a given NAICS code and a comment on how that number was derived need to be filed in the right place.

Update, 27 September 2026

A notice published 24 September 2026 (91 FR 60524, FR Doc. 2026-19546) extends the comment periods for both this methodology notice and the companion proposed rule by 60 days, to 20 November 2026. SBA states the extension took effect on filing on 21 September 2026, the original closing date, and attributes it to requests for more time and its own clarification of the impacts of the proposed changes. The methodology itself was not revised. Comments on the methodology still go to Docket No. SBA-2026-0265.

Primary sources

Small Business Size Standards: Revised Size Standards Methodology, 91 FR 54096 (20 August 2026): https://www.federalregister.gov/documents/2026/08/20/2026-17039/small-business-size-standards-revised-size-standards-methodology

Companion proposed rule, Small Business Size Standards, 91 FR 53741: https://www.federalregister.gov/documents/2026/08/20/2026-17042/small-business-size-standards

Extension of comment periods, 91 FR 60524 (24 September 2026): https://www.federalregister.gov/documents/2026/09/24/2026-19546/small-business-size-standards