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Is my trade business small enough? SBA size standards for construction and specialty trade NAICS codes

Updated October 28, 2026

For federal contracting, SBA sets the largest size a business can be and still compete for contracts set aside for small businesses, and it assigns a size standard to each NAICS code. [SBA, Get started with government contracting: size standards] Most building and heavy construction codes are capped at $45.0 million in average annual receipts and most specialty trade codes at $19.0 million, counting your affiliates too. [13 CFR 121.201, Small business size standards by NAICS industry] What matters on a bid is the one NAICS code in the solicitation, measured on the date you self-certify in your initial offer with price. [13 CFR 121.402, What size standards are applicable to Federal Government contracting programs?] [13 CFR 121.404, When is the size status of a business concern determined?]

What a size standard is

Size standards define whether a business entity is small and, thus, eligible for Government programs and preferences reserved for small business concerns. [13 CFR 121.101, What are SBA size standards?] SBA expresses each standard as either a number of employees or annual receipts in millions of dollars, and the figure is the maximum allowed for a concern and its affiliates to be considered small. [13 CFR 121.201, Small business size standards by NAICS industry] SBA establishes these standards industry by industry and publishes them with their NAICS codes at 13 CFR 121.201 and in its table of size standards. [FAR 19.102, Size standards and NAICS codes] [SBA, Table of size standards]

SBA says most non-manufacturing businesses with average annual receipts under $7.5 million will qualify as small, but there are exceptions by industry. [SBA, Get started with government contracting: size standards] Construction and specialty trades are among those exceptions, with much higher receipts limits.

The limits for construction and specialty trade codes

These are the receipts standards listed in 13 CFR 121.201 for common construction and trade NAICS codes. [13 CFR 121.201, Small business size standards by NAICS industry]

Two footnotes matter for trade firms. If a procurement requires the use of multiple specialty trade contractors and no specialty trade accounts for 50 percent or more of the value of the procurement, all of that work is treated as a single activity and classified as Building and Property Specialty Trade Services under 238990. [13 CFR 121.201, Small business size standards by NAICS industry] For dredging under 237990, a firm or its similarly situated subcontractors must perform at least 40 percent of the volume dredged with their own equipment or equipment owned by another small dredging concern. [13 CFR 121.201, Small business size standards by NAICS industry] Always confirm the current figure for your code in the regulation or the SBA table before you bid. [SBA, Table of size standards]

How SBA counts your annual receipts

Receipts means all revenue in whatever form received or accrued from whatever source, reduced by returns and allowances. Generally, that is total income (or gross income for a sole proprietorship) plus cost of goods sold, as reported on your IRS tax return. [13 CFR 121.104, How does SBA calculate annual receipts?] The only exclusions are the ones listed in the rule, such as net capital gains or losses, taxes collected for and remitted to a taxing authority, and proceeds from transactions with your affiliates. Subcontractor costs, reimbursements for purchases a contractor makes at a customer’s request, investment income, and payroll taxes may not be excluded. [13 CFR 121.104, How does SBA calculate annual receipts?] That matters for trade firms that pass a lot of money through to subs and suppliers.

If you have been in business for 5 or more completed fiscal years, your annual receipts are the total receipts over your most recently completed 5 fiscal years divided by 5. If you have been in business for less than 5 complete fiscal years, SBA takes the total receipts for the period you have been in business, divides by the number of weeks in business, and multiplies by 52. [13 CFR 121.104, How does SBA calculate annual receipts?] SBA generally relies on your federal income tax returns and any amendments filed on or before the date you self-certify. [13 CFR 121.104, How does SBA calculate annual receipts?]

Your affiliates count too

Concerns are affiliates of each other when one controls or has the power to control the other, or a third party controls or has the power to control both, and it does not matter whether control is exercised so long as the power exists. [13 CFR 121.103, How does SBA determine affiliation?] SBA looks at factors such as ownership, management, previous relationships with or ties to another concern, and contractual relationships. [13 CFR 121.103, How does SBA determine affiliation?] In determining your size, SBA counts the receipts or employees of your company and all of its domestic and foreign affiliates. [13 CFR 121.103, How does SBA determine affiliation?] For receipts, SBA adds your average annual receipts to the average annual receipts of each affiliate. [13 CFR 121.104, How does SBA calculate annual receipts?] If you own or control another business, add it in before you decide you are small.

Which NAICS code controls a bid

A concern must not exceed the size standard for the NAICS code specified in the solicitation. [13 CFR 121.402, What size standards are applicable to Federal Government contracting programs?] The contracting officer assigns one NAICS code and corresponding size standard by classifying the work in the one industry that best describes its principal purpose, and a procurement is usually classified according to the component that accounts for the greatest percentage of contract value. [FAR 19.102, Size standards and NAICS codes] The contracting officer applies the size standard in effect on the date the solicitation is issued. [FAR 19.102, Size standards and NAICS codes]

So you can be small for one job and not for another. A firm with receipts above the specialty trade limit may still be small on a job coded under a building construction code with a higher limit, and the reverse can knock you out. Check the NAICS code on every notice before you claim small status. Our federal contracting glossary explains NAICS and other terms you will see on a solicitation.

When your size is measured

You, including your affiliates, must qualify as small under the NAICS code assigned to a contract as of the date you submit a written self-certification that you are small as part of your initial offer or response which includes price. [13 CFR 121.404, When is the size status of a business concern determined?] Once awarded a contract as a small business, a firm is generally considered to be a small business throughout the life of that contract, though SBA rules on recertification can still apply. [13 CFR 121.404, When is the size status of a business concern determined?] A follow-on or renewal contract is a new contracting action, so size is measured again on your initial offer for it. [13 CFR 121.404, When is the size status of a business concern determined?]

Certification works a little differently. A company applying for SBA certification as a service-disabled veteran-owned small business must qualify as small as of the date of its application, under the size standard corresponding to any NAICS code listed in its SAM profile. [13 CFR 121.404, When is the size status of a business concern determined?] If you are working toward certification, see what to do after VetCert approval.

Representing your size and what happens if it is challenged

To be eligible for award as a small business, you must represent in good faith that you meet the size standard for the NAICS code identified in the solicitation. [FAR 19.301-1, Representation by the offeror] The contracting officer accepts that representation unless another offeror or interested party challenges it or the contracting officer has a reason to question it. [FAR 19.301-1, Representation by the offeror] If challenged, SBA evaluates your status and makes a determination that is binding on the contracting officer. [FAR 19.301-1, Representation by the offeror]

A protest by another offeror must be received by the contracting officer by the close of business of the fifth business day after bid opening or after the notice that identifies the apparently successful offeror, and it must give specific, detailed evidence that you are not small. [FAR 19.302, Protesting a small business representation] A protest filed by the contracting officer or SBA is always considered timely. [FAR 19.302, Protesting a small business representation] Keep your tax returns and affiliate information organized so you can answer one quickly.

If the NAICS code on a solicitation looks wrong

The contracting officer’s NAICS code designation is final unless appealed. An appeal of the NAICS code and size standard must be served and filed within 10 calendar days after the issuance of the initial solicitation or any amendment affecting the NAICS code or size standard. [FAR 19.103, Appealing the NAICS code and size standard determination] Appeals go to SBA’s Office of Hearings and Appeals, and an untimely appeal is dismissed. [FAR 19.103, Appealing the NAICS code and size standard determination] An interested party includes a business seeking to change the code so it can be considered small for the procurement, and the appeal must include a full and specific statement as to why the designation is erroneous. [13 CFR 121.1103, Appealing a NAICS code or size standard designation] For notices that come out before a solicitation, see our guide to sources sought notices.

Check your size before you bid

SBA offers a Size Standards Tool to check whether you qualify as a small business for government contracting purposes. [SBA, Size Standards Tool] SBA also points to the regulation and its table of size standards, and to SAM, where you can certify that your business is eligible for contracts that are reserved for small businesses. [SBA, Get started with government contracting: size standards] SBA’s table page also notes that businesses registered in SAM must update their SAM registration to have their small business status updated based on new size standards. [SBA, Table of size standards]

If you plan to use subcontractors on a set-aside, see our guide to limitations on subcontracting.

Common questions

What is the SBA size standard for electrical, plumbing, and HVAC contractors?
NAICS 238210 Electrical Contractors and Other Wiring Installation Contractors and NAICS 238220 Plumbing, Heating, and Air-Conditioning Contractors both have a size standard of $19.0 million in average annual receipts. [13 CFR 121.201, Small business size standards by NAICS industry]
What is the size standard for a general contractor on commercial buildings?
NAICS 236220 Commercial and Institutional Building Construction has a size standard of $45.0 million in average annual receipts. [13 CFR 121.201, Small business size standards by NAICS industry]
Do payments to my subcontractors count in my receipts?
Yes. Subcontractor costs may not be excluded from receipts. The only exclusions are those listed in 13 CFR 121.104, such as net capital gains or losses and taxes collected for and remitted to a taxing authority. [13 CFR 121.104, How does SBA calculate annual receipts?]
How many years of receipts does SBA average?
For a business with 5 or more completed fiscal years, SBA uses total receipts over the most recently completed 5 fiscal years divided by 5. A younger business uses total receipts divided by the number of weeks in business, multiplied by 52. [13 CFR 121.104, How does SBA calculate annual receipts?]
Can I bid as small if I am small under one of my codes but not the one on the solicitation?
No. A concern must not exceed the size standard for the NAICS code specified in the solicitation. If you believe the code is wrong, you can appeal it to SBA’s Office of Hearings and Appeals within 10 calendar days after the solicitation or amendment is issued. [13 CFR 121.402, What size standards are applicable to Federal Government contracting programs?] [FAR 19.103, Appealing the NAICS code and size standard determination]

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Sources

Checked against these sources on October 28, 2026. Rules change, so always read the current solicitation and regulation. This guide is general information, not legal advice.