Why Do SBA’s Newly Released Numbers Appear Distorted to Bolster its Size Standard Rule?

How many current federal contractors would gain small business status under SBA’s proposed size standard rule? SBA has given the public three answers.

Three counts. The proposed rule in the Federal Register says 37,002 firms now in the federal marketplace would become newly eligible. The Office of Advocacy’s press release says 4,000 to 6,000. SBA’s October 1, 2026, release says 2,924, or, elsewhere on the same page, fewer than 1,550.

Two percentages. The Rule says the change adds 1.8% more eligible small businesses, on a base of 6,344,967 firms. The October 1 release says 0.315%, dividing about 114,000 newly eligible firms by 36.2 million small businesses, including 29,811,495 firms with no employees. Same proposal, different base.

No stated method. None of the press release numbers appears in the Rule or in the methodology document. The release gives no method for any of its counts, and it leaves out the Rule’s own 1.8% and its base.

Tables that answer a different question. The release’s tables of ten large contractors and seventeen 8(a) participants show firms that are already small, drawn from the firms’ own self-selected profiles. They say nothing about who would gain small status under the proposal.

One estimate, two descriptions. Advocacy describes its 4,000 to 6,000 figure as current federal contractors. The October 1 release describes it as small entities that include nonprofits and local governments. Neither publishes the analysis.

A new office name. The Rule names Ryan Lambert as Associate Administrator, Office of Government Contracting and Business Development. The later extension notice and the October 1 release use Office of Industrial Base Resilience & Contracting. The Federal Register does not say who renamed the office, when, or under what authority.

What SBA has not published. Whether the Rule’s base excludes firms with no employees; how it derived 1,523, 1,401, or 2,924; the analysis behind Advocacy’s 4,000 to 6,000; and the source of the 56,725 contractor count.

Each estimate outside the Federal Register is smaller than its counterpart inside it, and none comes with math a reader can check.

Read the memorandum: Why Do SBA’s Newly Released Numbers Appear Distorted to Bolster its Size Standard Rule? (PDF)

Methodology and Citations. A companion paper gives the full citation and exact text for each of the eighteen figures in the memorandum, shows the arithmetic (114,541 ÷ 6,344,967 = 1.805%, nearly six times the release’s 0.315%; 4,000 to 6,000 ÷ 56,000 = 7.1% to 10.7%), and lists what could not be confirmed.

Read the Methodology and Citations paper: Methodology and Citations (PDF)