Small Business Association for International Companies Urges SBA to Withdraw Proposed Size Standards Rule

WASHINGTON, D.C. — September 30, 2026 — The Small Business Association for International Companies (SBAIC) is calling on the U.S. Small Business Administration (SBA) to withdraw its proposed small business size standards rule and finalize the standards it proposed in 2025 under its 2024 methodology.

The proposed rule, published August 20, would consolidate nearly 1,000 industry-specific size standards into 338 broader categories. For administrative and general management consulting (NAICS 541611), an industry code under which many SBAIC members compete, the receipts threshold would rise from $24.5 million to $295 million, twelve times its current level. When SBA applied its 2024 methodology in an August 2025 proposed rule, it set that same threshold at $27 million.

SBAIC members hold contracts ranging from $100,000 to $42 million. Under the proposal, a firm with nearly $300 million in annual revenue would compete for the same set-aside awards. SBA’s own analysis identifies 1,818 firms already holding federal contracts in that code that would become newly eligible as small businesses.

“The proposed size standard increases would let significantly larger and better-resourced companies compete in the same small business set-aside market as genuinely small firms,” said SBAIC Chair Betsy Bassan. “This would run counter to both the spirit and letter of the USG’s small business program, which exists to help nurture true small businesses given their deep importance to our economy and national security. The SBA should address middle market issues directly, not at the expense of the small businesses the USG has worked so hard to grow: it’s high time to create a robust but separate middle market program.”

SBAIC’s concerns center on several points.

• Impact on small businesses. The proposal would reclassify more than 114,000 mid-sized and large firms as small, including contractors that already earn billions in federal revenue. Traditional small businesses would have to compete against far better-capitalized firms and risk being pushed out of the federal market. A smaller small business base means less competition, less innovation, and higher costs for taxpayers.
• Methodology. The proposed methodology removes market factors SBA has long relied on and replaces six-digit industry standards with broad four- and five-digit categories. The result would classify some dominant firms as small and create a steep cliff for mid-tier firms.
• Process. The rulemaking warrants full adherence to statutory requirements set by Congress and coordination with related rulemakings now underway. Sharply higher size standards would also weaken Mentor-Protégé programs and make it easier to bundle contracts in ways that bypass small business protections.

The proposal also strains the statutory test it relies on: whether a firm is dominant in its field of operations. The new methodology defines that field as a broad geographic market. SBAIC’s members compete in a narrow one, U.S.-funded international assistance, with only a few buyers. Under the rule’s own logic, a smaller market warrants a smaller size standard, and the rule allows SBA to depart from its analytical results for specific industries. SBAIC asks the agency to do so here.

The deadline for comments has been extended to November 20, 2026. SBA published two linked proposals, and each needs its own comment: Docket SBA-2026-0199 (the proposed size standards) and Docket SBA-2026-0265 (the revised methodology). SBAIC encourages every affected firm to file, describing its own competitive position, the concrete effect of the change on its business, and recommended alternatives.

About SBAIC

The Small Business Association for International Companies (SBAIC) is a coalition of more than 150 small American businesses that serve U.S. international assistance programs. SBAIC members are located in Congressional districts across 41 states and are prime contractors on 80% of the work they implement, with contracts ranging from $100,000 to $42 million. Learn more at sbaic.org.

Contact: SBAIC Executive Committee, executive-committee@sbaic.org