Before SBA changes who counts as small, it should hear from you.
COMMENT PERIOD OPEN · SBA-2026-0199 + SBA-2026-0265 · CLOSES SEPTEMBER 21, 2026
On August 20 the Small Business Administration proposed the largest change to small business size standards in decades. Roughly 980 six-digit industry standards would be replaced by 338, most set at a broader level than the industry they measure today. Some industries would also change what is measured — from average annual receipts to employee count, or the reverse.
Comments close September 21. The U.S. Women's Chamber of Commerce® is filing in both dockets, and we are asking our members to file their own alongside ours.
What filing actually involves
File your comment on the size standards →
It takes about ten minutes, and you never face a blank page:
- Enter your six-digit NAICS code. You will see the current standard, the proposed standard, which other industries would share your ceiling, and — where it applies — whether your code is on the WOSB or EDWOSB designated list.
- Say where you stand. You are asked only the questions that fit your position.
- Answer a short set of questions about your market. Most are checkboxes, with room to add anything specific. You may get one or two follow-ups.
- Read both comments and edit anything. Nothing is submitted for you, and you may file without your name if you prefer. The tool never asks whether your business is certified.
The size standard is the gate to everything else
It is easy to read this as a technical rule about thresholds. It is not.
Whether a firm qualifies as small is the question that comes before every other question in the federal market. It decides who may bid on a small business set-aside. It decides the pool a woman-owned firm competes in when she does bid. Every program that follows sits on top of that determination, and this proposal changes it.
This affects you whether or not you are certified
The WOSB Federal Contract Program is limited to industries SBA has specifically designated — currently 733 six-digit NAICS codes, the list in effect since October 1, 2022. Each designation rests on a finding of underrepresentation that SBA makes one industry at a time, on evidence, and that Congress requires be reviewed on a five-year cycle.
Most women-owned firms are not working in those codes. If yours is not one of them, there is no designated channel where competition can be restricted to certified women-owned firms in your market.
That makes the size standard matter more to you, not less. You compete in the open small business pool, where the ceiling is the only line — and it is the line this proposal moves. A firm many times your size qualifying as small does not change your certification. It changes who is standing next to you when you bid.
If your industry is designated, the same ceiling governs who may compete for that work. The designation says which firms may compete; the size standard says how large they may be.
What SBA has not put in the record
The agency has not published the market analysis behind these groupings. It has also not shown, industry by industry, that a firm at the proposed size is not dominant in its field of operation — a finding the Small Business Act requires before any firm may be treated as small.
That gap is why individual comments matter here more than usual. What is missing from the record is exactly what only a business owner can supply: who you actually bid against, what a much larger competitor can do that you cannot, and what you committed — hiring, systems, certifications, capacity — because you expected to compete as a small business.
Write it your own way. When many comments share identical paragraphs, an agency can treat them as a single submission. Fifty women describing fifty different markets carry far more weight than five hundred copies of one letter. You do not need to agree with the Chamber to use the tool, and if a higher ceiling would help your firm, that belongs in the record too.
Two dockets, one deadline
Both filings are separate, and both close September 21. The tool prepares each one and links you to it.
- SBA-2026-0199 — the proposed size standards — read the docket
- SBA-2026-0265 — the methodology behind them — read the docket
File before September 21
Comments received after the closing date are not part of the record SBA must answer.