As such, that SME definition is only a small part of the wider picture. Since each country has different classifications and corresponding guidelines, it's important to carry out further research. Here are how several different jurisdictions define an SME differently, depending on the type of business.
How Do the EU and UK Define SMEs?
For the most part, the EU and the UK agree on how to define an SME. However, in 2022, the UK government changed the max employee count for an SME from 249 employees to 499 employees. Otherwise, the UK and EU governing bodies still share the same definitions for micro, small, and medium-sized enterprises. They are as follows:
- Micro businesses: 0 to 9 employees, with annual turnover (i.e. revenue) or a balance sheet not exceeding €2 million
- Small business: 10 to 49 employees, with annual turnover or a balance sheet not exceeding €10 million
- Medium business: 50 to 249 (EU) or 50 to 499 (UK) employees, with annual turnover under €50 million or a balance sheet under €43 million
In addition, the UK has different rules and definitions depending on the governing body. For example, the Companies Act 2006 codified the following different categories: micro entities, small companies, and medium-sized companies. As used by Companies House, each of these classifications has a different threshold to the ones mentioned above. Being aware of how these different classifications and categories impact you is critical when dealing with different agencies in the UK.
How Does the U.S. Define SMEs?
Compared to other countries, the U.S. often skews higher in its figures when defining an SME. A good reference point is the Small Business Administration (SBA), a U.S. government agency intended to assist small businesses. It classifies small businesses based on either average annual receipts or average number of employees.
To qualify as a small business, companies generally have to employ fewer than 500 employees. However, those size standards differ based on industry averages. Manufacturing tends to be higher, while wholesale trade is lower. Here are a few examples indicating the possible variance:
- Ice-cream and frozen dessert manufacturing: 1,000 employees
- Solar electric power generation: 500 employees
- Furniture merchant wholesalers: 100 employees
While the cap for defining an SME differs, the lower threshold is more consistent. The SBA normally identifies any company with fewer than 10 employees as small offices/home offices (SOHO).
How Does China Define SMEs?
The system for defining SMEs in China is complex, though it follows similar patterns to other jurisdictions. China’s SME Promotion Law 2003 considers three factors: the number of employees, total assets, and operating revenue. As with the U.S., the industry that a company works in further influences the boundary lines for each category. Here are a few examples of how different industries affect the thresholds.
The SME Promotion Law defines Chinese construction companies as:
- Small if they have fewer than 600 employees, under 40 million RMB total assets, and under 30 million RMB revenue
- Midsize if they have fewer than 3,000 employees, under 400 million RMB total assets, and under 300 million RMB revenue
Conversely, it defines Chinese retail companies as:
- Small if they have fewer than 100 employees and under 10 million RMB revenue
- Midsize if they have fewer than 500 employees and under 150 million RMB revenue