Keep NAICS research and small business size analysis separate

Published by Federal Bid Partners LLC · October 26, 2026 · Size standards

A NAICS code identifies an industry. It does not, by itself, establish that your business is small for a procurement. Keep the classification decision, applicable size standard, business-size calculation, and representation date as separate records.

13 CFR 121.201 provides SBA's size standards by industry and explains that the maximum applies to the concern and its affiliates. Standards generally use employees or annual receipts, with specified exceptions. Check the actual row, notes, and applicable rules rather than relying on a remembered threshold.

Start with the procurement record

Record the solicitation's designated NAICS code, stated size standard, issue date, and relevant amendments. Under FAR 19.102, the contracting officer assigns the procurement classification and applies the relevant size standard under the rule's timing provisions. Your preferred profile code does not replace that designation.

Then identify the measurement basis and calculation rules. An employee count at one moment or a single year's sales may not be the required measure. Do not use a worksheet designed for one standard as if it applies to every industry.

Fictional example: two different opportunities

Fictional Birch Analytics finds two solicitations involving related work but different designated industries. Its owner assumes the company's small-business answer will be identical. The analyst records each solicitation's code and standard, then asks finance for the data appropriate to each measure.

The review also identifies a related company that may require affiliation analysis. Birch does not simply omit that company because it has a separate name. It obtains qualified advice on the relevant facts before finalizing a representation. The resulting record explains the question, data, assumptions, and reviewer.

Keep your source trail

The SBA table resource links to standards and calculation guidance. Record the effective version you used. A downloaded file can remain on a shared drive long after a rule changes, so include the source date and review it against the solicitation.

For a decision with contractual consequences, use the applicable SBA rules and appropriate professional review. This article provides an organization method, not an automated size determination. The browser worksheet does not calculate affiliation or certify eligibility.

• Capture the designated procurement code and standard.
• Verify the standard's unit, notes, and effective version.
• Identify the applicable calculation period and rules.
• Collect supportable business and affiliate information.
• Record the relevant representation date.
• Resolve material uncertainties before representing size.

Finish with an explicit conclusion tied to the specific procurement and facts reviewed. Avoid turning that conclusion into an unlimited statement that the company is small for every federal contract. A reusable research record should make later reviews faster while leaving each new procurement's applicable requirements visible. Assign someone to revisit the analysis if an amendment changes the relevant designation or standard. Store the revised conclusion beside the earlier one, with a clear explanation of the change.