Regulatory Change Tracker

SBA Employee-Based Size Standards Review — Manufacturing and Defense NAICS (Proposed Rule)

SBA proposed adjustments to employee-based size standards for 120 NAICS codes in manufacturing, defense electronics, and shipbuilding sectors. Proposed increases of 50–250 employees per code to reflect industry consolidation and workforce growth since the 2019 review.

DoD Updated SDVOSB Subcontracting Goal Reporting Requirements (Policy Update)

DoD updated DFARS Subpart 219.7 to require large prime contractors on DoD contracts over $1.5M to submit SDVOSB subcontracting achievement data through the Electronic Subcontracting Reporting System (eSRS) using new reporting codes that separately track SDVOSB vs. VOSB subcontract dollars.

SBA All Small Mentor-Protégé Program Compliance Updates (Guidance)

SBA updated ASMP program guidance requiring protégés to demonstrate 'meaningful developmental assistance' in annual reviews. SDVOSBs in mentor-protégé agreements risk losing JV set-aside eligibility if annual performance certifications are not submitted on time.

SBA Size Standards Inflation Adjustment — Revenue-Based Standards (Final Rule)

SBA increased revenue-based size standards across most NAICS sectors by approximately 11–13% to reflect five years of cumulative inflation (2019–2024). SDVOSB-relevant professional services, IT, and construction codes are affected.

SBA Proposed Rule: SDVOSB Joint Venture Mentor-Protégé Alignment

SBA finalized updates aligning SDVOSB joint venture rules with the SBA All Small Mentor-Protégé Program. Changes clarify how SDVOSB JVs qualify for set-asides, manage work share requirements, and report performance to maintain program compliance.

FAR Update: SDVOSB Set-Aside Simplified Acquisition Threshold Clarification

FAR Council clarified that SDVOSB set-asides apply to acquisitions above the micro-purchase threshold ($10,000) and below the simplified acquisition threshold ($250,000) when the Rule of Two is met — reinforcing the requirement to consider set-asides for all competitive procurements.

SBA Revised Ownership and Control Standards for SDVOSB (Final Rule)

SBA updated 13 CFR Part 128 to clarify 'unconditional ownership' and 'control' requirements for SDVOSB eligibility. Key changes address managing member roles in LLCs, operating agreements, and supermajority voting thresholds.

VA Veterans First Contracting Program — Alignment with SBA VetCert (Policy Update)

VA updated its acquisition regulations to require contracting officers to verify SDVOSB and VOSB status through SBA's VetCert database (rather than the legacy CVE database) for all VA set-aside contracts effective January 1, 2024.

SBA VetCert Three-Year Recertification Cycle (Guidance Update)

SBA clarified that all SDVOSB and VOSB participants in VetCert must recertify every three years. Annual representations and certifications in SAM.gov do not substitute for the VetCert recertification requirement.

SBA Takes Over SDVOSB/VOSB Certification from VA (Final Rule)

SBA assumed sole authority to certify SDVOSBs and VOSBs nationwide. Businesses previously certified by the VA Center for Verification and Evaluation (CVE) were required to migrate to SBA's Veteran Small Business Certification (VetCert) program by December 31, 2023.