According to a document published on September 24, 2026, in the Federal Register (doc. 2026-19546, 91 FR 60524), the SBA has extended the comment deadline for both of its August proposals: the general overhaul of small business size thresholds (document SBA-2026-0199) and the new methodology for determining those thresholds (SBA-2026-0265). The original deadline, set upon the publication of the proposals on August 20, 2026, was September 21. The SBA cited incoming requests from the industry for additional time to comment and the need to clarify the impact of the proposed changes as the reasons for the extension.
What is at stake
The SBA’s August proposal consolidates nearly 1,000 existing, narrow small business size thresholds into 338 groups, based primarily on 4- and 5-digit NAICS codes. For some industries, the SBA also proposes changing the metric from annual revenue to number of employees. The effect: as many as 110,000 to 114,500 companies that currently do not qualify as “small” would gain this status—along with access to set-aside federal contracts, SBA loan programs, and other preferences.
Who asked for more time
The request for an extension was submitted by the American Subcontractors Association (ASA), representing construction subcontractors. In a letter to the SBA sent in the week before the original September 21 deadline, the ASA argued that the industry needs more time to realistically assess the impact of the changes. Main concerns: combining specialized categories—such as drywall, painting, or flooring work—into broader NAICS groups could force companies with completely different business models to compete for the same contracts; and shifting to an employee-based metric, given high revenue volatility in construction, may not accurately reflect a company’s true economic size.
Why this matters for Polish companies in the US
The proposal affects every Polish company in the United States that applies or plans to apply for federal contracts or uses SBA loan programs—from construction and subcontracting companies to IT services and light manufacturing. A change in NAICS classification can, on the one hand, open up access to new contracts reserved for small businesses, and on the other hand, put a smaller company in competition with significantly larger entities that will also qualify as “small” after the threshold change.
For companies that have been following the topic since the August announcement and failed to react before the original September 21 deadline, this is a second chance to submit comments before the changes are finalized into regulations.
What to do before November 20
- Check your own NAICS code and compare it with the new list of 338 groups in proposal SBA-2026-0199—the threshold may have changed from revenue-based to employee-based.
- Assess whether the threshold change opens up access to new federal contracts reserved for small businesses or rather increases competition in a given industry.
- Submit a comment via regulations.gov under document number SBA-2026-0199 (thresholds) or SBA-2026-0265 (methodology)—every comment goes into the material upon which the SBA will draft the final rule.
- If in doubt, consult the impact of the change with an accountant or a federal contracts advisor.
Polish businesses and service providers supporting entrepreneurs in the United States can be found in the Polish Pages directory.
