We ran the numbers on our own code. In NAICS 541611, across FY2021 through FY2025, eighty-five parent companies sit between the current size standard and the proposed one. Together they hold $23.44 billion in federal obligations.
The median firm among them has won one hundred percent of that work through unrestricted competition. Sixty of the eighty-five are at or above ninety-five percent.
Read that again, because it is the whole story. The firms about to become eligible for small business set-asides in management consulting are, on the evidence of the award record, firms that have never had to win one.
What SBA actually proposed
On August 20, 2026, SBA published two companion documents in the Federal Register. The first is a revised methodology white paper explaining how the agency would calculate size standards going forward. The second applies that methodology to produce new thresholds.
Three changes matter for federal services contractors.
The first is consolidation. Roughly 995 standards spread across 978 six-digit NAICS industries, plus 18 subindustry exceptions, would collapse into 338 standards set at the four- and five-digit level. Management consulting no longer gets its own line. NAICS 541611 would fall under the 5416 group and take that group's standard.
The second is the size of the increase. That 5416 standard is proposed at $295 million in average annual receipts, against the current $24.5 million for 541611. Engineering services would move from $25.5 million to $252 million. Custom computer programming would go from $34 million to $531 million. Environmental consulting, currently $19 million, would land at the same $295 million as management consulting.
The third is structural. The ceiling that has capped receipts-based standards comes off, and a productivity adjustment enters the calculation for the first time. Every existing exception disappears, including the information technology value-added reseller carve-out and its 150-employee test. Construction moves to employee-based measurement entirely.
SBA is not proposing to lower any standard. Its own analysis pointed toward a decrease in 45 industries and it declined to make those cuts. Nobody currently small becomes other-than-small through this rule.
The number nobody is publishing
SBA estimates the two rules together would newly classify roughly 114,500 businesses as small, including about 37,000 that held federal contracts in FY 2025 worth approximately $71 billion. Secondary analysis of the rule puts more than 1,800 of those firms in 541611.
Those are national counts of firms, and they answer a question no capture lead is asking. The question that matters is narrower: in the codes I bid, which specific companies cross back over the line, how much work do they already hold, and have they ever competed for a set-aside?
We built a tool to answer it, because we needed the answer ourselves.
The eighty-five figure above is what it returns for 541611. It is a different measure than SBA's count and deliberately so. It works from the public award record rather than company financials, consolidates a parent company's identifiers so one firm reads as one firm, and uses a five-year average matching the averaging period the regulation uses. That last point matters more than it sounds. A firm operating under a dozen identifiers looks mid-sized under any single one and is often well above the threshold combined.
The caveat is real and we state it in the tool: federal contract dollars are not company receipts. A firm's total receipts include commercial work, and affiliation rules pull in entities the award record does not show. Nothing this produces is a size determination, and only SBA and the contracting officer make those. What it produces is an estimate of who is likely in the band, and a precise account of how those firms have been winning work.
The competition history is the part that changes the argument. "More firms become eligible for set-asides" sounds like the small business program working. Eighty-five firms with a median unrestricted win rate of one hundred percent is a different sentence entirely. These are not small businesses that grew. They are firms that built capture organizations for full and open competition and are about to bring them into a lane built for someone else.
The counterargument is fair and worth stating. The same rule extends your own runway. A firm at $22 million that would have graduated out of small business status in three years now has room to grow for a decade. That is a genuine benefit, and it is why plenty of mid-tier firms support the change. Whether it outweighs the near-term competitive hit depends on where you sit today, which is exactly why generic industry positions are useless here and your own figures are not.
The trap
Do not update your size representation in SAM.gov.
This is a proposed rule. No size standard has changed. A firm that self-certifies as small under a threshold that does not yet exist has made a false certification, and the exposure runs through the False Claims Act. Wait for a final rule, wait for its effective date, confirm your status under the applicable affiliation rules, then update.
Affiliation is the part people skip. Your revenue is not the test. Your revenue plus your affiliates' revenue is the test, and a firm that looks comfortably small alone can fail once affiliates count. If you are in a joint venture, under a mentor-protégé agreement, or carrying common ownership across entities, model the affiliate-inclusive number before drawing any conclusion.
Recertification deserves its own attention. The rules that took effect earlier this year already made size status a recurring question rather than an annual one, particularly around transactions. If you are contemplating a deal, work the interaction between recertification timing and a possible final rule through with counsel rather than reasoning about it from a blog post.
Before September 21
Comments on Docket SBA-2026-0199 are due September 21, 2026. That is eleven days from publication. Check the docket for current status before relying on the date.
SBA had already received more than 65,000 comments as of early this month, and volume is not the variable. The agency must respond to significant comments. It is not obligated to be persuaded by a form letter, and a comment saying the rule is bad for small business will be counted and set aside.
Specificity is what carries. A useful comment names your NAICS code, describes your firm in revenue and headcount terms, and quantifies the change in your competitive position. Say how many firms enter your code and what they already hold. Describe the procurements you compete for and what the bidder pool looks like today against what it would look like after. If you can identify a specific unintended consequence, name the mechanism.
Comment on the methodology as well as the thresholds, under Docket SBA-2026-0265. The threshold is one number in one year. The methodology sets every number for years afterward.
Run it on your own codes
The Size Standard Impact Tool is free, runs in your browser, and works on any NAICS code and any pair of thresholds. Type the codes you compete in — the award data is already loaded, so there is nothing to download or reconcile first. It returns the cohort, the competition breakdown for each firm, a confidence rating on every estimate, and a workbook.
Then it drafts the comment. You choose the position — oppose, support, support with modifications, or take no position and submit the data alone — and it assembles a letter built on your figures in an unbranded Word document, ready for your letterhead. The tool takes no position on the rule. The analysis measures. The argument is yours.
There is an eleven-page user guide covering both routes into the analysis, how to read the results, the two-person figure verification step, and the cautions. Start there if you plan to file.
The rule may not survive in this form, and sixty-five thousand comments suggest it will not survive untouched. But the direction of travel is legible, and the firms that have modeled both worlds will make better decisions in either one.