SBA's Huge Size Standards Increases: Are they too much?

SBA published proposed size standards that raise small-business limits by 15x in some important industries. As I explained in my live stream earlier, the across-the-board increases flow from SBA’s interpretation of the “dominance” provision in the Small Business Act. SBA explains that, for $20 billion industries, a $500 million business “would not be dominant.” That’s why the proposed size standards go up to $531 million in some important government contracting industries, and even higher in others.

An auto-generated transcript of the live stream follows.

Links

* Google Sheet comparing the proposed standards to current standards and previously proposed standards https://docs.google.com/spreadsheets/d/1lY83yT6T-THskHao-Vf28JrryhKay-XP

* SBA Proposed Rule on Small Business Size Standards https://www.federalregister.gov/documents/2026/08/20/2026-17042/small-business-size-standards

* SBA Proposed Size Standards Methodology https://www.federalregister.gov/documents/2026/08/20/2026-17039/small-business-size-standards-revised-size-standards-methodology

* Prior SBA proposed changes from August 2024 https://www.govinfo.gov/content/pkg/FR-2025-08-22/pdf/2025-16142.pdf

* Prior SBA Size Standard Methodology https://legacy.sba.gov/sites/default/files/2024-09/Updated_Size_Standard_Methodology_WhitePaper_2024_Proposed_508_v0.pdf

* Link for Submitting comments by September 21, 2026 https://www.regulations.gov/commenton/SBA-2026-0199-0001

* How Big is Small? The Economic Effects of Access to Small Business Government Support by Matthew Denes et. al. https://papers.ssrn.com/sol3/papers.cfm?abstract_id=3451424

Chapters

* 0:00 Breaking News: SBA Proposes a Sweeping Overhaul of Size Standards

* 1:17 Sam’s Background at SBA

* 3:02 What the Law Requires: Defining “Small”

* 5:49 Two Types of Size Standards: Employees vs. Receipts

* 8:52 Procedural Requirements: NAICS Codes and Public Hearings

* 11:44 Walking Through the Proposed Numbers

* 18:12 How These Numbers Got So Big: The Old Methodology

* 21:19 The New Methodology and the $500 Million Anchor

* 26:08 Footnotes and Sub-Industries Eliminated

* 30:42 What This Means: Mid-Sized Companies Become Small

* 33:05 Second-Order Effects: The Rule of Two and Set-Asides

* 36:52 Contract Consolidation, M&A, and the Mentor-Protégé Program

* 41:23 Timeline: The Comment Period and Path to a Final Rule

* 47:57 Audience Q&A: SBIR, Loan Programs, and Multi-Award IDIQs

* 50:33 The Old Maximum Cap, and Research on Raising Size Standards

* 54:07 Effects on Subcontracting and Certification Programs

* 56:07 The Dominance Standard and How to Submit Comments

* 58:41 Closing Thoughts: Sam’s Take

With over 20 years of Federal legal experience, Sam Le counsels small businesses through government contracting matters, including bid protests, contract compliance, small business certifications, and procurement disputes. Sam received his law degree from the University of Virginia and formerly served as SBA’s director of procurement policy. His website is http://www.samlelaw.com.

This video is for informational purposes only and does not constitute legal advice.