# How does SBA count employees for its size standards?

**Short answer:** SBA averages everyone you employed, full-time, part-time or temporary, across each pay period in the last 24 completed calendar months. Staffing agency and professional employee organization workers count, and so do affiliates' employees (13 CFR § 121.106).

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Last checked: 2026-11-08

SBA counts every person you employ, and part-time and temporary workers count the same as full-time workers. 13 CFR § 121.106 uses an average over time, not your headcount today.

## The calculation

Take the number of employees for each pay period in the preceding 24 completed calendar months, then average them (§ 121.106(b)(1)). If you have been open less than 24 months, average the pay periods you have been in business (§ 121.106(b)(3)).

## Who counts

- Full-time, part-time and other employees.
- People supplied by a temporary agency, professional employee organization or leasing company (§ 121.106(a)).
- Employees of your domestic and foreign affiliates (§ 121.106(b)(1)).

Volunteers who receive no compensation, including no in-kind compensation, do not count. SBA weighs the totality of the circumstances, including IRS criteria, to decide who is an employee. So a 1099 label does not settle the question.

## When this applies

Employee-based limits in 13 CFR § 121.201 appear for manufacturers and wholesalers, among others. Machine shops (NAICS 332710) have a limit of 500 employees. Industrial supplies wholesalers (NAICS 423840) have a limit of 125.

Form 1919 separately asks for your existing employee count. It includes owners, all part-time and full-time staff, and all affiliates' employees, not converted to full-time equivalents.

## Sources

- [13 CFR § 121.106](https://www.ecfr.gov/current/title-13/section-121.106)
- [13 CFR § 121.201](https://www.ecfr.gov/current/title-13/section-121.201)
- [SBA Form 1919 (02/2025)](https://legacy.sba.gov/document/sba-form-1919-borrower-information-form)