AI in Procurement  /  Tooling  /  Size Standard Impact Tool

When a rule changes who counts as small, the argument is won with data. This tool produces it — from the public award record, in your browser, for free.

NAICS Size Standard Impact Tool

See who enters your competitive pool, and put it on the record

SBA has proposed raising size standards across most of the economy. When a threshold moves, firms that are too large to count as small today become small — and they arrive in the set-aside pool with the capture infrastructure they built competing in the open market. This tool identifies those firms from public contract data, shows how each of them competes today, and drafts a comment to SBA built on your own figures. Type the NAICS codes you compete in — the award data is already loaded.

Overview

The rule is public. The effect on your market is not.

SBA’s proposed rule would replace roughly a thousand six-digit size standards with 338 set at the four- and five-digit level, remove the ceiling that has capped receipts-based standards, and add a productivity adjustment for the first time. By SBA’s own estimate, about 114,541 firms would newly be classified as small, of which roughly 37,002 held federal contracts in FY 2025.

Those are national numbers. They tell you nothing about your market. The question a capture lead actually needs answered is narrower: in the codes I compete in, which specific firms cross back over the line, how much work do they already hold, and have they ever had to win a set-aside?

This tool answers that from the public award record. Enter your NAICS codes and it returns every parent company whose measured federal receipts fall between the current and proposed thresholds — a five-year average across a company’s whole federal book, matching the averaging period the regulation uses — and a breakdown of how each firm has been winning work: full and open competition against each category of set-aside.

In the first run we published, covering NAICS 541611 across FY2021 through FY2025, the answer was 85 firms holding $23.44 billion in obligations — and the median firm among them had won 100 percent of that work through unrestricted competition. Sixty of the 85 were at or above 95 percent. Whatever your position on the rule, that is a different fact pattern than “more small businesses will be eligible,” and it is the kind of specific, sourced observation an agency has to respond to.

The tool then drafts the comment. You choose the position — oppose the increase, support it, support it with modifications, or take no position and submit the data alone — and it assembles a comment built on your figures, in a plain Word document with no branding, ready to paste into your own letterhead.

It runs in your browser, it is free, and it works on any NAICS code and any pair of thresholds — not only the rule in front of us now.

The NAICS Size Standard Impact Tool results screen for NAICS 541611, showing four summary figures — companies in the band, companies above the threshold, cohort obligations, and median unrestricted share — with the cohort table visible beneath.
NAICS Size Standard Impact Tool · Results for NAICS 541611, FY2021–FY2025 Eighty-five firms fall between the current and proposed thresholds; the median firm has won all of its work through unrestricted competition. Estimates from public award data, not size determinations.
Data partner

Built on federal award data prepared by MakeGov

MakeGov

The award data behind this tool is prepared by MakeGov, Inc. using Tango, their unified API for U.S. federal contracting data. Tango draws on SAM.gov, USAspending, FPDS, DSBS, GSA eLibrary, Grants.gov, GAO bid protests and agency forecasts, and resolves entities across UEI and DUNS identifiers so that one company reads as one company rather than several records that happen to share a name.

That entity resolution is the hard part of this analysis. A large firm operating under a dozen identifiers looks mid-sized under any one of them, and a tool that misses the connection returns a plausible list of the wrong companies. Tango handles it upstream, which is why users type a NAICS code instead of downloading and reconciling a spending extract.

Tango unifies SAM.gov, USAspending, FPDS, DSBS, GSA eLibrary, Grants.gov, GAO bid protests and agency forecasts behind a single API key. Built for developers, priced for builders.

What it does

Eight things it handles for you

Any NAICS code

Not just the codes in front of SBA today. Give it any code and any two thresholds and it runs the same analysis.

The regulatory measure

A five-year average, matching the averaging period at 13 CFR 121.104 — not a run-rate that answers a different question.

Company identity, resolved

Large firms operate under many identifiers. They are consolidated before the analysis runs and every merge is listed in the workbook, because a firm that looks mid-sized under one identifier is often well above the threshold combined.

Competition history

The share of each firm’s work won through open competition versus each category of set-aside. Usually the most telling number in a run.

Confidence, stated

Every firm carries a rating for how reliable its estimate is. The largest firms are usually the least reliable, and the tool says so.

It will not guess a threshold

Codes that look related carry different standards. Where the tool doesn’t have one, it stops and says which code it needs rather than producing a plausible wrong answer.

Figure verification

A sign-off form covering every figure a run produced, for two people to complete before anything is published or filed. One unsupported number gets a whole comment discounted.

Comment drafting, position-neutral

You choose the position. The tool writes to it and checks that every number in the draft traces back to a source.

Start with the guide

NAICS Size Standard Impact Tool — User Guide

Eleven pages covering both routes into the analysis, running it, reading the results, verifying figures, and drafting the comment. Also the cautions — chiefly that federal contract dollars are not company receipts, and what that means for how the output can be used.

Download the User Guide (PDF)
How to get started

Three steps

01 //

Enter your NAICS codes

Type the codes you compete in, separated by commas. The federal award data is already loaded, so there is nothing to download first.

02 //

Run the analysis

Confirm the thresholds and the tool returns the cohort, the competition breakdown, and a workbook you can download.

03 //

Verify, then file

Complete the sign-off form against your sources, choose your position, and draft the comment. Paste it into your letterhead and submit it at regulations.gov.

Need a scope, date range, or reporting-delay cutoff the prepared data doesn’t cover? You can still supply your own USAspending extract — the option is on the first screen, and the file is read in your browser and never uploaded.

Comment deadline

Docket SBA-2026-0199 closes 21 September 2026

SBA must receive comments on or before 21 September 2026. Agencies must respond to significant comments, and a specific objection supported by data is significant in a way that sentiment is not. Check the docket for current status before relying on that date.

Online

Submit through the Federal eRulemaking Portal at regulations.gov. The button above opens the comment form for this docket directly. If you navigate there yourself, search for Docket No. SBA-2026-0199 or RIN 3245-AI67.

By mail or hand delivery

Ryan Lambert, Associate Administrator, Office of Government Contracting and Business Development, 409 Third Street SW, Mail Code 6530, Washington, DC 20416. Reference RIN 3245-AI67 or Docket No. SBA-2026-0199.

Comments are posted publicly. If your submission contains confidential business information, SBA directs that it be sent separately to GCBDregs@sba.gov with “RIN 3245-AI67” in the subject line, marked and explained, for SBA to review before any release.

Credit

Built and maintained by The Wolverine Group, Inc. Award data prepared by MakeGov, Inc. using the Tango API — https://www.makegov.com. Regulatory citations are dated and resolve to the Federal Register and the Code of Federal Regulations; verify each against the source before relying on it.

The Size Standard Impact Tool is an independent analytical aid — not an official Government system, and not legal, financial, or tax advice. It produces estimates from public federal spending data. It does not and cannot determine any firm’s size status under the Small Business Act or 13 CFR Part 121, and its output is not a size determination or certification. Size standards, size determinations, affiliation, and eligibility rest with the U.S. Small Business Administration and the contracting officer, and turn on facts not present in this data — including total receipts from all sources and the receipts of affiliates. Proposed rules are subject to change or withdrawal and confer no rights; nothing here should be read as a recommendation to alter a size representation, certification, teaming arrangement, or bid strategy. MakeGov, Inc. is not responsible for the analysis, the conclusions drawn from it, or any comment filed using it.

The tool takes no position on the rule. The analysis measures; it does not argue. The position in any comment is the filer’s own.

More tools in development

We build what our own practitioners need first, then release it. If a repeatable task in your shop would benefit from the same treatment, tell us — it shapes what we build next.

Get started

Find out who is coming into your market

Free. Browser-based. Enter your NAICS codes.

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