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New SBA Rule on Small Business Size and Status Recertification and Its Impact on GovCon M&A
A new SBA rule on small business size and status recertification was issued by the U.S. Small Business Administration (SBA) in December 2024, consolidating its requirements into a single regulation codified at 13 CFR 125.12. Because of the far-reaching implications of this new rule, the SBA is delaying the implementation of certain provisions until January 17, 2026. Both buyers and sellers considering a M&A transaction involving an affected small business entity have ample incentive to get a deal done in 2025 so that required recertifications can be made before that date.