06/19/2026
LUNCH AND LEARN
NAICS CODE 101
Workshop Summary - NAICS Codes Must Match the Work Sought
Per Case Law Review- the solicitation's NAICS code must be based on the principal purpose of the work the government seeks to acquire. The contracting officer assigns the NAICS code that best describes the predominant products or services required under the solicitation. Therefore, the NAICS code selection is driven by the government's requirement—not by the contractor's preferred business classification or primary line of work.
The Issue
For contractors, the practical issue is whether they qualify as a small business under the NAICS code assigned to the solicitation. A contractor is not automatically disqualified simply because the solicitation's NAICS code differs from the NAICS code under which the contractor most commonly operates. Contractors frequently perform work across multiple industries and may demonstrate that their experience, capabilities, and past performance are closely related to the work being procured. If challenged, the contractor must be prepared to articulate how its qualifications, experience, and resources align with the solicitation requirements.
The key distinction is this: the solicitation's NAICS code must match the work sought by the government, while the contractor must demonstrate its ability to perform that work and, when applicable, meet the size standard associated with the assigned NAICS code.
Therefore, the issue is not whether the contractor's preferred NAICS code matches the solicitation, but whether the contractor can legally compete under the assigned NAICS code and substantiate its capability to perform the required work if questioned by the agency, competitors, or the SBA.
Training Takeaway
The solicitation's NAICS code must match the government's requirement. The contractor's responsibility is to demonstrate capability and eligibility under that assigned NAICS code—not to require the government to use the contractor's preferred NAICS code."
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