SBA Size Standards by NAICS: 2026 Table, Steps & Appeals

By Aoba Works · Published October 23, 2026 · 18 min read

How this guide was made: drafted with AI assistance from the official sources linked below, then passed an automated editorial check before publishing. Our process

• Federal Contracting
• Sam.gov

The SBA sets a size standard for each NAICS code. It's the largest your company can be, measured in average annual receipts or in employees, and still count as "small" for a contract classified under that code. To check it, find the 6-digit NAICS code on the solicitation, look that code up in the SBA's Table of Size Standards (the version in effect since March 17, 2023), and compare the cap with your company-wide receipts or headcount, including affiliates (SBA, SBA table). A firm can be small under one code and "other than small" under another. That means the code on each solicitation decides which set-asides you can bid on, not the code you like best.

Which option is right for you?

Start with the question that fits your situation, and open the first page listed in the table.

Why these picks: beginners need accurate codes before anything else. Active bidders lose the most when they misjudge size on a single solicitation. Multi-industry firms are the ones most likely to be small under one code and large under another.

What Are SBA Size Standards by NAICS Code?

SBA size standards by NAICS code set the maximum average annual receipts or employee count a firm can have to be "small" in that industry. The SBA says that size standards "define the largest size a business can be to participate in government contracting programs," and that most manufacturers with 500 or fewer employees and most non-manufacturers with average annual receipts under $7.5 million qualify as small, though many industries have higher limits (SBA).

Each standard is attached to a 6-digit code from the North American Industry Classification System (NAICS). The regulation that lists them all is 13 CFR 121.201. The SBA publishes the same data as a PDF and an Excel file. The table version in effect as of October 2026 is dated March 17, 2023 (SBA table page). The SBA counts 995 separate size standards today (Mayer Brown).

Three rules apply to every code:

• The cap is company-wide. You measure the whole business against the cap, plus every affiliate. The SBA says you "must include the employees or receipts of all affiliates" (SBA). You don't split your revenue by NAICS code.
• Some codes have exceptions. For example, 541330 Engineering Services has a $25.5 million cap, but its exception for military and aerospace equipment and military weapons is $47.0 million (13 CFR 121.201).
• Each contract carries one code. The contracting officer assigns one NAICS code and its size standard to each solicitation, contract and order (FAR 19.102).

How to Find Your NAICS Code and Matching Size Standard

First find the NAICS code that best matches each product or service you sell. Then look up that code in the SBA table to get the employee or receipts cap. The SBA notes that a business "will generally have a primary NAICS code, but it can also have multiple NAICS codes if it sells multiple products and services" (SBA).

Step-by-step lookup

1. Search the Census NAICS tool. Go to census.gov/naics, type a plain keyword into the NAICS search box (for example, "janitorial" or "software"), and choose the 2022 NAICS year. That's the edition behind the current SBA table. Open each result and read the full description, including the "cross-references" that tell you which activities belong somewhere else.
2. Write down every code that fits real revenue. For each candidate code, ask whether you've actually earned money from that work or can show past performance in it. Leave out codes you're only hoping to grow into.
3. Get the cap. Download the Excel version of the SBA Table of Size Standards and filter the NAICS column for your codes. The PDF and 13 CFR 121.201 contain the same numbers. Check the footnotes for exceptions.
4. Run the SBA tool as a cross-check. The SBA Size Standards Tool asks "Do you qualify as a small business for government contracting purposes?" and walks you through code and size inputs. It gives you a quick answer, not a formal determination.
5. Enter the codes in SAM.gov. In your entity registration, add the codes and choose a primary NAICS. When you select at least one small business code, SAM.gov asks for Size Metrics (receipts and employees) and uses them to show your size status for each code (SAM.gov entity checklist). If you aren't registered yet, follow our SAM.gov registration guide.

Common mistakes and fixes

• Mistake: using a code from your state license or tax return without checking it. Fix: read the Census definition. A code that's close enough for tax purposes can carry a very different cap.
• Mistake: reading the 4- or 5-digit industry group. Fix: size standards attach to the 6-digit code (and sometimes to an exception under it). Always check all six digits.
• Mistake: using an old PDF of the table. Fix: confirm that the file name or header says "Effective March 17, 2023," or a later date if the SBA issues a new final rule.

SBA Size Standards by NAICS Code: Employees vs. Revenue Table

Manufacturing and wholesale codes mostly use employee caps. Services, construction and retail codes mostly use average annual receipts. The numbers below come from 13 CFR 121.201 as of October 2026. Check the official page before you bid, because a proposed overhaul is pending (covered below).

Two things in this table catch people out.

Codes that sound alike can have different caps. Electrical contractors (238210) are capped at $19.0 million, while a general contractor on commercial buildings (236220) gets $45.0 million. Engineering (541330) sits $8.5 million below computer systems design (541512).

The ITVAR exception changes the measure entirely. For 541519, an IT value-added reseller is measured by employees (150), not receipts. The exception applies only when value-added services make up at least 15% and no more than 50% of the contract price (13 CFR 121.201).

For supply contracts where you resell rather than manufacture, a firm can still be small with 500 or fewer employees if it meets the nonmanufacturer rule (13 CFR 121.402).

How to Choose the Right NAICS Code When Your Business Spans Multiple Industries

Make your primary NAICS code the activity that brings in the most revenue. Then list every other code you can honestly perform, even where you're too large. You don't pick a contract's code. The contracting officer does. So the real decision is which opportunities you go after and how you present your registration.

Why "choose the most favorable cap" doesn't work

You can't earn a bigger cap by naming a different code as primary. On any solicitation, your size is measured against the code the contracting officer assigned, which is based on "the principal purpose of the product or service being acquired" (13 CFR 121.402). Your SAM.gov primary code matters elsewhere. Several SBA programs check it. Under 13 CFR 121.404, a firm applying to programs such as 8(a), HUBZone, WOSB or SDVOSB must "qualify as small under the size standard corresponding to any NAICS code listed in its SAM profile." Agencies also tend to search SAM by NAICS when they do market research. A primary code that doesn't match your track record leads to mismatched outreach and weaker past-performance stories.

Steps for a multi-industry firm

1. Split your last 5 fiscal years of revenue by activity. Use your own books, for example invoices tagged by service line. This tells you which activity is really primary.
2. Calculate one company-wide size figure. Do this once, using the methods in the receipts section below. Your size is the same number no matter which code you test it against.
3. Compare that number with every code's cap. Put your codes in a simple sheet with three columns: code, cap, and small (yes or no).
4. Make the highest-revenue activity your primary code. If two activities are close, choose the one where you have the strongest past performance.
5. Keep every honest code in SAM, including the ones where you're large. You can still compete on full-and-open contracts and act as a subcontractor under those codes. SAM.gov shows your status per code.
6. Point your set-aside search at the codes where you're small. In SAM.gov Contract Opportunities, filter by NAICS Code and Set Aside, and save searches only for the "yes" codes.

Example (illustrative numbers)

An IT and engineering firm has 5-year average receipts of $28.0 million. It's small under 541512 ($34.0M cap) and other than small under 541330 ($25.5M cap), unless an engineering solicitation uses the military and aerospace exception ($47.0M). The firm makes 541512 its primary code because most of its revenue comes from systems design. It keeps 541330 listed and bids on engineering set-asides only when the solicitation names the $47.0M exception.

Pitfalls

• Adding codes you can't support. Being listed doesn't make you eligible, and the claim can backfire in a size or responsibility review. Keep to work you've done or can clearly staff.
• Forgetting that size is tested at the offer. Size is fixed on the date you submit your "initial offer or response which includes price" (13 CFR 121.404). A large year can tip you over just before a big bid. Recalculate before every set-aside proposal.

How NAICS Code Choice Affects Set-Aside Eligibility

The NAICS code on a solicitation decides which size standard applies. So the same firm can be eligible for one set-aside and shut out of another. When you submit a bid on a set-aside, or register as small, you're legally certifying your size (13 CFR 121.108). Read the code before you decide to bid.

Where to read the code

On a SAM.gov opportunity page, look at the Classification block. NAICS Code and Set Aside (or Original Set Aside) are shown together. The solicitation document repeats the code and size standard in its representations and certifications.

Example (illustrative)

A specialty electrical contractor averages $24.0 million in receipts. An agency posts a total small business set-aside under 238210 ($19.0M cap). The firm is other than small and can't bid as a small business. A month later, another agency posts a renovation project as a small business set-aside under 236220 ($45.0M cap). Now the same firm is small. Nothing about the company changed. Only the code changed. If you're still deciding between total and partial set-asides, see our total vs partial set-aside checklist.

Socioeconomic programs use the same test

Size eligibility for SDVOSB, WOSB and 8(a) set-asides also depends on the solicitation's NAICS code. For the program-specific requirements, see our SDVOSB eligibility checklist and our 8(a) pass/fail checklist.

What happens if a competitor thinks you're too big

Any interested offeror can file a size protest. It has to reach the contracting officer by close of business on the 5th business day after bid opening (sealed bids) or after notice of the apparent awardee (negotiated buys). The SBA dismisses protests that arrive late (13 CFR 121.1004). Contracting officers and the SBA aren't bound by that window (13 CFR 121.1004). Keep your receipts and payroll workpapers ready before you bid so you can answer one.

Use sources-sought notices to influence the code

During market research, you can tell the agency which code fits the work and why. A well-argued sources-sought response is the cheapest way to head off a bad code before the solicitation is posted. Our sources sought response template has a spot for this.

SBA NAICS Small Business Size Standards: 2026 Updates

As of October 2026, no new final size standards have taken effect this year. The March 17, 2023 table still applies. In August 2026, though, the SBA proposed a major overhaul. The last inflation adjustment to receipts-based standards was published November 17, 2022, and the SBA adjusts for inflation at least once every five years (Federal Register, Aug. 20, 2026).

What the August 20, 2026 proposal would change

The SBA published a proposed rule (RIN 3245-AI67, docket SBA-2026-0199) and a methodology notice (docket SBA-2026-0265). Comments were due September 21, 2026 (Mayer Brown; Federal Register). The main points:

• 995 size standards would shrink to 338, mostly at the 4- or 5-digit NAICS level instead of 6 digits.
• All 18 federal contracting exceptions would be removed.
• Employee-based standards would become the default (208 of the 338). Receipts-based standards would cover 129, and one would be asset-based.
• Receipts-based standards would be adjusted for inflation and for productivity growth, using nominal GDP per employee.
• New minimums would be 500 employees or $30.6 million in receipts (Holland & Knight).

Source: Mayer Brown summary of the proposed rule.

The SBA estimates that about 114,541 more firms would qualify as small, including 37,002 current federal contractors holding about $71 billion in FY2025 obligations (Mayer Brown).

What this means for you right now

• Bid on today's numbers. "Current size standards remain in effect unless and until final rules are issued" (Mayer Brown). If you certify under a proposed cap, you're misrepresenting your size.
• If you're small today, plan for more competition. If the proposal is finalized as drafted, much larger firms would be eligible for the same set-asides.
• Watch the NAICS edition too. OMB asked for comments on proposed NAICS 2027 updates on July 13, 2026 (Federal Register). The SBA usually adopts new NAICS editions in its size standards, so some codes may be renumbered later.
• After any final rule, update SAM.gov. When the 2023 table took effect, the SBA reminded firms that they "must update their SAM registration in order to have their small business status updated" (SBA table page).

How to Calculate Average Annual Receipts for Size Standard Purposes

Average annual receipts are your total receipts over the last 5 completed fiscal years, divided by 5. The few exclusions are listed in 13 CFR 121.104. The SBA's plain-language version: total income plus cost of goods sold from your federal tax returns, averaged over the latest five complete fiscal years (SBA).

Steps

1. Pull your last 5 filed returns. Use completed fiscal years only. The year in progress doesn't count.
2. For each year, add total income and cost of goods sold as reported on the return.
3. Subtract only the allowed exclusions: net capital gains or losses, taxes collected and remitted to a taxing authority, proceeds from transactions between affiliates, and amounts collected for another party by travel agents, real estate agents, advertising agencies, freight forwarders and customs brokers. The rule says these "are the only exclusions" (13 CFR 121.104). Pass-through subcontractor costs aren't on the list, so they stay in.
4. Add your affiliates' receipts for the full period, including those of a firm you acquired partway through. Leave out a former affiliate if the affiliation ended before the date size is determined (13 CFR 121.104).
5. Divide by 5. If you've been in business less than 5 years, divide total receipts by the number of weeks in business and multiply by 52 (13 CFR 121.104).

Example (illustrative numbers)

Receipts for FY2021–FY2025: $22M, $26M, $30M, $31M, $36M. Total $145M ÷ 5 = $29.0M. Under 541512 ($34.0M) this firm is small. Under 541330 ($25.5M) it isn't. If someone used only the latest year ($36M), they'd wrongly conclude the firm is large for both codes.

Employee-based codes

For employee caps, average the number of employees across all pay periods in the preceding 24 completed calendar months. Part-time and temporary staff count the same as full-time, and workers supplied through PEOs and leasing firms can count too (13 CFR 121.106). For example, a machine shop (332710, 500-employee cap) that peaked at 540 people last summer may still be small if its 24-month average is under 500.

Pitfalls

• Using net income or "revenue" from a management dashboard. Use the tax-return figures.
• Counting only the parent entity. Affiliation from ownership, common management or economic dependence pulls other firms' numbers in (see FAQ).

What to Do If You Disagree With a Contract's Assigned NAICS Code

If you think a solicitation's NAICS code is wrong, file a NAICS code appeal with the SBA's Office of Hearings and Appeals (OHA) within 10 calendar days after the solicitation, or the amendment that changed the code, is issued (13 CFR 121.1103). If you don't appeal in time, the contracting officer's designation is final (FAR 19.102).

Steps

1. Mark the deadline on day one. Count 10 calendar days from the issue date, weekends included. OHA dismisses appeals that come in late (13 CFR 121.1103).
2. Ask the contracting officer first. Point out the mismatch in writing, quoting the Census NAICS definition. An amendment fixes things faster than an appeal. Keep the clock in mind while you wait, though.
3. Build the argument around "principal purpose." Show which component accounts for the largest share of contract value, using the statement of work and the factors in 13 CFR 121.402: the NAICS Manual descriptions, the solicitation's description, and the relative value of the components.
4. Include the required contents: the solicitation number, the contracting officer's name and contact details, your identifying information, and "a full and specific statement as to why the NAICS code designation is erroneous, and argument in support thereof" (13 CFR 121.1103).
5. File with OHA. The regulation lists OHA, U.S. Small Business Administration, 409 3rd Street SW, Suite 5900, Washington, DC 20416. Check OHA's current filing instructions before you send it.
6. Expect the deadline to be paused. When an appeal is received, the contracting officer must stay the date for receipt of offers (13 CFR 121.1103).

Pitfalls

• Appealing because you want a bigger cap. OHA asks what the government is buying, not which code helps you. Argue from the statement of work.
• 8(a) sole-source awards. Only the SBA's Associate Administrator for Business Development may appeal those (13 CFR 121.1103).
• Assuming unrestricted buys can't be appealed. They can. Appeals are allowed whether or not the procurement is reserved for small businesses (13 CFR 121.1103).

Next steps

Do these today:

1. Download the Excel Table of Size Standards and make a sheet with your codes, their caps, and a yes/no for whether you're small.
2. Work out your 5-year receipts average (or 24-month employee average) from filed returns and payroll, including affiliates, and save the workpapers.
3. In SAM.gov Contract Opportunities, save a search filtered by NAICS Code (your "yes" codes only) and Set Aside.

If you'd rather not do this yourself:

• APEX Accelerators (formerly PTACs) offer no-cost counseling on NAICS selection, SAM.gov and bid preparation (APEX Accelerators). They're a good fit for first-time bidders. They're less useful if you need a legal opinion on affiliation or help with an active protest, because counselors don't represent you.
• A government contracts attorney is the right call for affiliation questions, a size protest you received, or an OHA appeal. Fees are set by each firm, so ask for a written estimate or flat fee up front (as of October 2026; check with the firm). If your question is just "which code fits my services," an attorney is more than you need.

Related guides on this site:

• SAM.gov Registration Guide: 7 Steps From UEI to Active
• Capability Statement Example: 5 Sections Buyers Read First: put your NAICS codes where buyers look first
• Total vs Partial Small Business Set Aside: 2026 Checklist

FAQ

What is the SBA size standard for my industry?

Look up your 6-digit NAICS code in 13 CFR 121.201 or the SBA's March 17, 2023 table. For example, 541511 Custom Computer Programming is $34.0 million in receipts, and 336411 Aircraft Manufacturing is 1,500 employees. Check footnotes for exceptions, such as the $47.0 million exceptions under 541330.

How often does SBA update size standards?

The SBA reviews size standards over multi-year cycles and adjusts monetary standards for inflation at least once every five years. The last adjustment was published November 17, 2022 (Federal Register). A broad overhaul was proposed in August 2026 but isn't final. Today's caps still apply.

Can a business use different NAICS codes for different contracts?

Yes. You can list multiple codes in SAM.gov. On each contract, you're measured against the code the contracting officer assigned, which is one code per contract, or per discrete category on multiple-award contracts (13 CFR 121.402). You can't pick a different code for a contract yourself. The only route is a timely NAICS appeal.

What happens if I misrepresent my size status?

Submitting a bid on a set-aside counts as an affirmative certification of size. Willful misrepresentation can lead to a presumption of loss equal to the full amount spent on the contract, suspension or debarment, False Claims Act liability, and criminal penalties (13 CFR 121.108). Good-faith reliance on an SBA advisory opinion gives you some protection.

How do affiliation rules affect my size standard calculation?

The SBA adds together the receipts or employees of your firm and all its domestic and foreign affiliates. Affiliation can come from 50%+ ownership, common management, family firms that do business with each other, or getting 70% or more of receipts from one other firm over three fiscal years (13 CFR 121.103). What matters is the power to control. It doesn't have to be used.

Sources

• SBA: Size standards (contracting guide)
• SBA: Table of Size Standards (effective March 17, 2023)
• SBA: Size Standards Tool
• 13 CFR 121.201: Size standards by NAICS
• 13 CFR 121.103: Affiliation
• 13 CFR 121.104: Annual receipts
• 13 CFR 121.106: Employees
• 13 CFR 121.108: Penalties for misrepresentation
• 13 CFR 121.402: NAICS designation
• 13 CFR 121.404: When size is determined
• 13 CFR 121.1004: Size protest time limits
• 13 CFR 121.1103: NAICS code appeals
• FAR 19.102: Size standards and NAICS codes
• Federal Register: Small Business Size Standards (proposed rule, Aug. 20, 2026)
• Federal Register: Revised Size Standards Methodology (Aug. 20, 2026)
• Federal Register: NAICS proposed updates for 2027 (July 13, 2026)
• Mayer Brown: SBA proposes major overhaul of size standards
• Holland & Knight: SBA proposes sweeping overhaul
• SAM.gov Entity Registration Checklist
• U.S. Census Bureau: NAICS search
• APEX Accelerators

Spotted something out of date or wrong? Tell us at shigoto.ai.note@gmail.com. Guides are re-checked against official sources on a rolling schedule.