Choosing NAICS Codes for Government Contracting
How NAICS codes and size standards work in federal procurement, and how to keep yours current
A NAICS code classifies a business by industry. In federal contracting, each solicitation carries one NAICS code chosen by the contracting officer, and that code's size standard decides whether an offeror counts as small for that procurement. Companies list every NAICS code that fits their work in SAM.gov and designate one as primary.
What Is a NAICS Code?
The North American Industry Classification System assigns six-digit codes to industries. The Small Business Administration ties a size standard to each code, measured either in average annual receipts or in number of employees, depending on the industry. NAICS is revised every five years, with the next revision scheduled as NAICS 2027.
How NAICS Codes Work in a Solicitation
For each solicitation, the contracting officer selects the single NAICS code that best describes the principal purpose of what is being bought. To compete as a small business, an offeror must not exceed the size standard for that code. A firm can be small under one code and other than small under another, so the same company may qualify for one set-aside and not the next.
Multiple-award contracts can assign different codes to different categories of work, and each order under them carries a single code. An offeror that believes a solicitation's code is wrong can appeal to SBA's Office of Hearings and Appeals, but the appeal must be filed within 10 calendar days of the solicitation's issuance.
Why the Codes in Your SAM.gov Registration Matter
The codes a company lists in SAM.gov support its size representations and shape how agencies and primes find it during market research. Some SBA programs, including 8(a), also look to the firm's primary NAICS code for certain determinations.
SBA defines a firm's primary industry by where its activity is concentrated, weighing factors such as the distribution of receipts, employees, and costs across its lines of business.
How to Choose NAICS Codes for a Consulting or Contracting Business
Start with where the revenue comes from and what the company intends to bid. List every code that accurately describes work the company performs, and designate as primary the code that reflects the largest share of its business.
Much business and management consulting falls under 541611, Administrative Management and General Management Consulting Services, with related specialties elsewhere in the 5416 group, such as 541613 for marketing consulting and 541618 for other management consulting. General contractors usually fall in the 2361 group for residential building or 236220 for commercial and institutional building, with heavy and civil construction in the 237 group. Confirm each code against the NAICS manual and SBA's current table of size standards.
Keeping Codes Current
Revenue mix shifts as a company grows, and size standards change when SBA updates them. SBA determines size as of the date a company submits its initial offer including price, so a registration that was accurate last year can misstate the company's position this year.
Reviewing NAICS codes and size status once a year, and again before any major set-aside pursuit, keeps the registration aligned with the business.
Frequently Asked Questions
What NAICS code should a business consulting firm use?
Most business and management consulting falls under 541611, Administrative Management and General Management Consulting Services. Related consulting specialties have their own codes in the 5416 group, such as 541613 for marketing consulting.
What NAICS code does a general contractor use?
It depends on the type of construction. Commercial and institutional building is 236220, residential building falls in the 2361 group, and heavy and civil engineering construction falls in the 237 group.
Can I compete as small under a NAICS code that isn't my primary code?
Yes. Size is measured against the size standard for the NAICS code in the solicitation. Your primary code does not limit which set-asides you can pursue, though you need to represent your size accurately for the solicitation's code.
Can a contracting officer's NAICS code be challenged?
Yes. An offeror or other interested party adversely affected by the designation can appeal to SBA's Office of Hearings and Appeals within 10 calendar days after the solicitation, or an amendment affecting the code, is issued.