A theoretical maximum achievable signal to noise ratio (SNR) for piezoelectric microphones is identified as a function of only microphone volume irrespective of architecture and construction details. For a given piezoelectric material, microphone SNR can be reduced to an expression containing only a dimensionless coupling coefficient and microphone volume. For a given material, the coupling coefficient has a theoretical upper bound defined by the most favorable deformation geometry. The ability to identify a theoretical maximum SNR as a function of only microphone size is surprising considering the numerous design variables and infinite design freedom afforded in the microphone design stage.