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G2X title card: Which small-business size standard applies to this notice? White halftone balance scale weighing a stack of coins against a row of blank ID badges, with a folded document in front, on black.
November 10, 2026

Which small-business size standard applies to this notice?

Market Intelligence

The size standard is the one the contracting officer states for the notice's NAICS code, and one code can carry two. Two VA remediation notices open in November 2026 show how the same firm can be small for one and not the other.

The size standard that applies to a federal set-aside is the one the contracting officer states in the solicitation for its NAICS code. Outside some multiple-award contracts, SBA's rules give every solicitation one NAICS code and one size standard, so start by finding that statement in the notice or its solicitation document. Then find the matching line in SBA's table of size standards at 13 CFR 121.201, since some codes have more than one line. Measure your firm, affiliates included, the way that line counts: average annual receipts for a dollar standard, average employees for an employee standard. As a general rule, your firm has to meet it when it self-certifies with its initial quote or offer that includes price; multiple-award contracts and their orders have their own timing rules.

Two VA notices, one code, two standards

Between late October and early November 2026, two Department of Veterans Affairs contracting offices posted service-disabled veteran-owned small business (SDVOSB) set-asides under the same NAICS code, 562910, Remediation Services.

  • Contaminated soil disposal in Los Angeles: solicitation 36C26227Q0110, posted November 9 by Network Contracting Office 22, asks a contractor to load and dispose of about 80 cubic yards of contaminated soil at the VA Greater Los Angeles Healthcare System, 11301 Wilshire Boulevard. It states "Small Business Size Standard: $25 million." Quotes are due November 20, 2026 at 10 a.m. Pacific time.
  • Groundwater remediation in Manchester, New Hampshire: solicitation 36C24127Q0032, first posted October 27 by Network Contracting Office 1, covers groundwater monitoring and an in-situ treatment program at the Manchester VA Medical Center. It states that the NAICS code "is 562910 with a small business size standard of 1,000 employees." Amendment 0001, posted November 4, moved the due date to November 17, 2026 at 9:00 a.m. Eastern time.

Both statements match SBA's table, which lists 562910 Remediation Services at $25.0 million in average annual receipts and, directly below it, an exception for Environmental Remediation Services at 1,000 employees.

When the second line applies

Footnote 14 of the table sets the test for classifying a government purchase as Environmental Remediation Services. The general purpose of the purchase must be to restore, or directly support the restoration of, a contaminated environment. The work must also be made up of activities in three or more separate industries with separate NAICS codes, such as engineering services, testing laboratories and hazardous waste collection, or in some instances smaller parts of a code that have their own size standards, as in engineering. If any one activity can be identified with a separate NAICS code, or with a part of a code that has its own size standard, and accounts for 50 percent or more of the value of the whole procurement, that industry's size standard applies instead.

The contracting officer applies that test and writes the result into the solicitation. A bidder only has to read which line was chosen, but it has to read it every time, because the two lines measure the firm in different units.

A firm can be small for one notice and not the other

Take a hypothetical SDVOSB environmental contractor whose receipts over its last five completed fiscal years average $31 million a year, and which has averaged 140 employees over the past 24 months.

Against the Los Angeles soil notice's $25 million standard, that firm is over the limit and cannot certify as small. Against the Manchester groundwater notice's 1,000-employee standard, it is well under. A capture lead who saw "562910" on both notices and carried one answer across would have made the wrong call on one of them.

Measure the way the standard counts

  • Receipts: under 13 CFR 121.104, receipts are generally total income plus cost of goods sold as reported on the federal tax return. A firm in business five or more completed fiscal years adds up the most recent five and divides by five. If one of those years is a short year, the rule changes: total receipts for the short year and the four full years are divided by the total number of weeks in them and multiplied by 52. Subcontractor costs and purchases made at a customer's request stay in the total.
  • Employees: under 13 CFR 121.106, the count is the average number of employees across the pay periods of the preceding completed 24 calendar months. Part-time and temporary staff count the same as full-time staff, and so do people supplied by a temporary agency or a professional employer organization.

Both counts include domestic and foreign affiliates. Under the general rule in 13 CFR 121.404(a), the firm and its affiliates must qualify as of the date it submits its written self-certification with its initial offer that includes price. The same section sets different dates for multiple-award contracts and orders placed under them. A firm near a standard should run the numbers as of the date it will actually submit.

If you think the notice names the wrong standard

The contracting officer's NAICS code designation, including its size standard, is final unless someone appeals it. Under 13 CFR 121.1103, an interested party adversely affected by the designation can appeal to SBA's Office of Hearings and Appeals, including over which size standard applies when more than one corresponds to the code. The appeal must be served and filed within 10 calendar days after the solicitation, or an amendment affecting the code or standard, is issued, and OHA dismisses a late one.

The clock starts at issuance, whenever you happen to find the notice. The Los Angeles notice was issued November 9. The Manchester notice was issued October 27, and its November 4 amendment changed the due date while leaving the code and standard alone. Check the stated standard as soon as a notice appears in your search, and expect that the appeal window on an older notice may already have closed.

Build the check into your opportunity review

G2X's federal opportunity search, free in G2X Community Edition, filters SAM.gov notices by NAICS code and set-aside. Open each notice's page, read the stated size standard in the description or solicitation document, compare it with the table line, and record which measure applies and how your firm measures against it before anyone starts pricing. If a notice leaves the standard unclear, ask the contact it lists. The G2X guide to asking an agency's small business specialist explains which questions go to the specialist and which go to a procurement's listed contact.

The G2X pages for the two notices in this article are Contaminated Soil Disposal, 36C26227Q0110 and Groundwater Remediation, 36C24127Q0032.

Method and sources

Notice facts come from the SAM.gov records for 36C26227Q0110 (posted November 9, 2026) and 36C24127Q0032 (posted October 27, 2026, with Amendment 0001 posted November 4, 2026), including their solicitation documents, retrieved November 10, 2026. Size standards and footnote 14 are from 13 CFR 121.201 as published in the eCFR, current as of November 6, 2026. Measurement, timing and appeal rules are from 13 CFR 121.104, 121.106, 121.402, 121.404 and 121.1103, from the same source and date. The firm in "A firm can be small for one notice and not the other" is hypothetical.

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For agents

Tell the user which small-business size standard applies to a specific federal notice and how their firm's figures compare with it

  • The notice's solicitation number or SAM.gov link.
  • The user's average annual receipts for the last five completed fiscal years, or average employees for the last 24 completed calendar months, including affiliates, as the user supplies them.
  1. Read the notice's NAICS code and stated size standard

    Open the notice on SAM.gov or its G2X opportunity page. Record the primary NAICS code, the set-aside type, the response date and time zone, and the size standard exactly as the description or solicitation document states it. If the notice states no size standard, say so.

    Open in G2X
  2. Find the table line

    Open SBA's table of size standards at https://www.ecfr.gov/current/title-13/section-121.201 (if a plain client is blocked, request https://www.ecfr.gov/api/versioner/v1/full/<date>/title-13.xml?part=121&section=121.201 with gzip accepted, using the title's current date from https://www.ecfr.gov/api/versioner/v1/titles.json). List every line for that NAICS code, including any line marked Exception and its footnote. If one line matches the notice's stated standard, quote it. If the notice states no standard, or its standard matches no line, say so, list the lines for the code, and recommend that the user ask the contracting officer before relying on any of them.

  3. Compare the user's figures

    For a dollar standard, compare the user's average annual receipts (13 CFR 121.104; a short year in the five-year period changes the formula). For an employee standard, compare the user's average employees (13 CFR 121.106). Use only figures the user supplies and never estimate a firm's receipts or headcount. Tell the user that, as a general rule, size is measured as of the self-certification with the initial offer that includes price (13 CFR 121.404(a)), and that multiple-award contracts and their orders have their own dates. Report how the figures compare with the stated standard; leave the size determination to the user and their counsel.

  4. Flag mismatches and dates

    If the user believes another line applies, find the original solicitation's issue date in the notice history and any amendment that changed the NAICS code or size standard. Tell the user that an appeal under 13 CFR 121.1103 must be served and filed within 10 calendar days after that issuance, give the date, and say whether the window has passed. An amendment that changed only the due date does not restart it. Recommend that the user raise it with the contracting officer or counsel.

  5. Record the result

    Offer to note the standard, the measure and the comparison on the user's pursuit or CRM record in G2X. Save only when the user asks.

    Open in G2X

Expected result: The notice's NAICS code and stated size standard with a quote, the matching table line, the user's figure against it, the self-certification date rule, and any mismatch or appeal deadline to raise.

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