The SBA $10 million loan limit took effect on July 4, 2026, under a policy notice from the U.S. Small Business Administration (SBA). Under it, one qualified borrower can hold up to $10 million in SBA 7(a) and 504 loans combined, according to SBA news release 26-69 of July 7, 2026.
It matters to any business whose plans run past the old $5 million cumulative cap, and to small manufacturers, who have their own 504 rule. SBA Policy Notice 5000-879058, published May 18, 2026, spells out the order. A lender may approve a 7(a) loan first, with the 504 transaction approved second by a Certified Development Company (CDC). This article walks through that sequence, the limits behind it, and the questions the notice leaves to your lender.
The $10 million figure is not one loan. It is two programs with separate statutory limits, used in sequence: up to $5 million through 7(a), then up to $5 million through 504. Small manufacturers and qualifying energy projects can go to $5.5 million per 504 project. The per-loan maximums did not change, and who counts as a qualified borrower is decided in underwriting, not in the releases.
Can I get more than $5 million in SBA loans?
Yes, since July 4, 2026, if you qualify for both programs. SBA news releases 26-52 and 26-69 say a qualified borrower who secures a 7(a) loan first may access up to $5 million through 7(a). That borrower may then access up to $5 million through 504, a combined $10 million. Each loan is still underwritten separately.
Before July 4, the cumulative 7(a) and 504 limit for one borrower was $5 million, according to release 26-52. Administrator Kelly Loeffler said in release 26-69 that "SBA's loan limits have not been raised for more than a decade." The policy notice frames the change as a clarification rather than a new ceiling. SBA now recognizes the 504 program's separate statutory limit, so lenders may issue 7(a) and 504 loans one after the other.
Our company site covers the announcement itself in SBA $10 million loan limit 2026. This article stays on the borrower's three questions: can I, in what order, and when will a lender say yes.
What the SBA $10 million loan limit changed, and what it did not
The notice, addressed to SBA employees, 7(a) lenders and CDCs, starts from the two statutes. Under 15 U.S.C. 636(a)(3)(A), the gross amount of any single 7(a) loan may not exceed $5,000,000. The notice also records the cap on the outstanding SBA-guaranteed balance to one borrower, including affiliates: $3,750,000, or $4,500,000 for a qualifying export loan. Under 15 U.S.C. 696(2)(A), one borrower's 504 debenture balance may not exceed $5,000,000 for standard projects, or $5,500,000 per project for small manufacturers and qualifying energy projects.
What changed is how the two limits interact. The notice says a borrower's outstanding 7(a) balance, up to the 7(a) maximum, does not reduce the amount available under 504, with exceptions stated in the notice. To figure the 504 limit, a CDC counts only the 504 loans the applicant and its affiliates have received, committed or outstanding. Nothing in the notice raises the maximum for a single 7(a) loan or a single 504 debenture.
The notice revises SOP 50 10 (Lender and Development Company Loan Programs) at Section C, Chapter 1, Paragraph D and at Appendix 3. It carries an expiration date of August 1, 2027.
| Program | Limit the notice records | What the money can pay for | Place in the sequence |
|---|---|---|---|
| 7(a) | $5,000,000 gross for any single 7(a) loan; $3,750,000 outstanding SBA-guaranteed balance to one borrower and its affiliates | Working capital, real estate, machinery and equipment, changes of ownership, refinancing business debt (SBA 7(a) page) | First. The lender approves the 7(a) loan. |
| 504, standard project | $5,000,000 aggregate outstanding debenture balance per small business concern, counting only its 504 loans | Long-term fixed assets: land, buildings, construction, renovation, machinery and equipment; not working capital or inventory (SBA 504 page) | Second. A CDC approves the 504 transaction with a senior lender. |
| 504, small manufacturer | $5,500,000 for each eligible project; primary North American Industry Classification System (NAICS) code in sector 31, 32 or 33, all production facilities in the United States | The same fixed assets; a facility and a production line may be financed at the same time as separate projects | Same CDC approval. The releases add up to $5 million through 7(a) and state no order. |
| 504, qualifying energy project | $5,500,000 per project, up to $16,500,000 outstanding for such projects per small business concern | Projects that cut energy use by at least 10 percent, or that generate renewable energy or renewable fuels | Same CDC approval. These loans do not reduce the $5,000,000 standard limit. |
SBA's 504 program page, read November 4, 2026, lists $5.5 million as the maximum for a 504 loan, while its header says up to $5 million. The policy notice reconciles them. $5,000,000 is the standard aggregate limit per small business concern, and $5,500,000 applies per project for small manufacturers and qualifying energy projects. The news releases describe the combined cap using the $5 million figure.
7(a) first, then 504: the order the notice describes
The sequence is the heart of the notice. It says a lender may first approve a 7(a) loan, followed by a 504 transaction approved by the CDC second. The example it gives is a business that uses 7(a) for working capital and light equipment while using 504 to finance its facility. The notice does not describe the reverse order, a 504 loan first and a 7(a) loan after it. It also does not define the term qualified borrower that the news releases use. Both questions sit with the lender and the CDC.
Sort the uses by program
7(a) proceeds can cover working capital, real estate, machinery and equipment, ownership changes and refinancing of business debt. 504 proceeds cover long-term fixed assets only; the SBA 504 page rules out working capital and inventory.
The 7(a) loan is approved first
You apply through an SBA lender, not SBA itself. The 7(a) page says you will always work directly with your lender. The lender approves the loan within the $5,000,000 gross limit and the guaranteed-balance cap.
The 504 transaction is approved second
A CDC originates the 504 loan together with a senior lender; the 504 page says 504 loans are available only through CDCs. The debenture limit counts the 504 loans the applicant and its affiliates have received, committed or outstanding, and nothing else.
Each project stands on its own
Under the revised definition, a 504 Project is the purchase, lease, improvement or renovation of one or more long-term fixed assets with 504 financing. Separate 504 loans may finance separate projects at the same time, subject to the debenture limits.
SBA loans for small manufacturers: a separate rule
Small manufacturers had a wider 504 lane before July 4, and the releases keep it. Release 26-52 says small manufacturers can secure an unlimited number of 504 loans as long as each loan is tied to a distinct project. It adds that they will also be able to apply for $5 million through 7(a). The notice puts a figure on each project: $5,500,000 per eligible project. It defines a small manufacturer by two tests: a primary NAICS code in sector 31, 32 or 33, and all production facilities located in the United States.
The notice also lets one 504 Project include several assets financed at the same time, subject to the debenture limits. It names the case it has in mind: a small manufacturer buying a facility and a production line together, each needing its own financing. Release 26-69 also lists loan fee waivers for manufacturing NAICS codes and a 90 percent Made in America Loan Guarantee. Those programs have their own terms and are not covered here.
The releases say the number of 504 loans is unlimited; the notice gives a dollar figure per project and no count. A CDC applies the definitions file by file.
When will a lender say yes?
The releases say qualified borrower; the notice says small business concern and applicant. None of the three documents defines qualified, and none promises that a borrower who fits under the cap will be approved. The 7(a) page puts it plainly: "You will always work directly with your lender and not with SBA." The yes comes from two underwriters, a lender for the 7(a) loan and a CDC with a senior lender for the 504 loan, each reading its own file.
Both files draw on the same records: business tax returns, financial statements, a debt schedule and projections tied to the use of proceeds. Our article on what lenders check before they say yes walks through the order an underwriter reads them in. With a stacked request the second file is read after the first loan is approved, so the 7(a) payment appears on the debt schedule the CDC reviews.
For the two programs compared side by side, down payments, guarantee percentages and closing times, see 7(a) or 504: which one fits your deal. For what a packaged file looks like, see our SBA 7(a) and 504 loan packaging and loan package preparation pages.
- Does the lender approve the 7(a) loan first and then hand the 504 transaction to a CDC, as the notice describes
- Which affiliates count toward the $3,750,000 guaranteed-balance cap and toward the 504 debenture limits
- Does the business meet the small manufacturer definition: primary NAICS code in sector 31, 32 or 33, all production facilities in the United States
- Is each asset a separate 504 Project, or one Project with several assets, under the revised definition
- How the lender treats a request where the 504 loan would come first; the notice does not describe that order
This article explains what the SBA releases, Policy Notice 5000-879058 and the SBA program pages say, as read on November 4, 2026. It is not lending or legal advice. Your lender and your CDC decide the limits, the order of approval and your eligibility, so confirm them with your lender before you plan around a figure.
Planning a request above $5 million?
SMAART Loans builds the financial package behind 7(a) and 504 applications and matches it to SBA lenders and Certified Development Companies. Call 1-800-382-1040 or start with the form.
Talk to a loan advisorFrequently asked questions
Yes, since July 4, 2026. SBA news releases 26-52 and 26-69 say a qualified borrower who secures a 7(a) loan first may access up to $5 million through 7(a). The same borrower may then access up to $5 million through 504, a combined $10 million. Each loan is approved separately, the 7(a) by a lender and the 504 by a Certified Development Company.
That is the order the SBA releases and Policy Notice 5000-879058 describe: a lender approves the 7(a) loan first, then a Certified Development Company approves the 504 transaction. None of the documents describes the reverse order or says what happens to a borrower who already holds a 504 loan. Your lender applies the notice to your file.
No. It is the combined total of two separate loans under two programs with their own statutory limits. The maximum for a single 7(a) loan is still $5 million, according to SBA's 7(a) program page. The standard 504 debenture limit per borrower is still $5,000,000, per the policy notice. The $10 million figure is what the two add up to for a borrower who qualifies for both.
Policy Notice 5000-879058 sets $5,500,000 as the 504 maximum for each eligible project of a small manufacturer. That business must have its primary NAICS (North American Industry Classification System) code in sector 31, 32 or 33, with all production facilities in the United States. SBA release 26-52 says small manufacturers can secure an unlimited number of 504 loans tied to distinct projects, plus up to $5 million through 7(a).
No. SBA's 504 program page still limits 504 proceeds to long-term fixed assets such as land, buildings and machinery, and it still rules out working capital and inventory. The notice adds that one 504 Project may include several eligible assets financed at once, for example a facility and a production line. Working capital stays on the 7(a) side.
Sources
- U.S. Small Business Administration, Policy Notice 5000-879058, Coordination of 7(a) and 504 for Maximum Loan Limits, published May 18, 2026, effective July 4, 2026. https://legacy.sba.gov/document/policy-notice-5000-879058-coordination-7a-504-maximum-loan-limits
- U.S. Small Business Administration, news release 26-52, SBA Doubles Cumulative 7(a) and 504 Loan Limit to $10 Million, May 18, 2026. https://legacy.sba.gov/article/2026/05/18/sba-doubles-cumulative-7a-504-loan-limit-10-million
- U.S. Small Business Administration, news release 26-69, Small Businesses Now Eligible for $10 Million in SBA Financing, July 7, 2026. https://legacy.sba.gov/article/2026/07/07/small-businesses-now-eligible-10-million-sba-financing
- U.S. Small Business Administration, 7(a) loans program page. https://www.sba.gov/funding-programs/loans/7a-loans
- U.S. Small Business Administration, 504 loans program page. https://www.sba.gov/funding-programs/loans/504-loans
- 15 U.S.C. 636(a)(3)(A) and 15 U.S.C. 696(2)(A), Legal Information Institute. https://www.law.cornell.edu/uscode/text/15/636 and https://www.law.cornell.edu/uscode/text/15/696
- SMAART Company, SBA $10 Million Loan Limit 2026. https://www.smaartcompany.com/blog/sba-10-million-loan-limit-2026
