That's a good question. Truthfully, we really don't know for certain. There are a lot of Gymnotus species, and for most of them, the only data we have is from the original description. Most descriptions are based on only a handful of specimens, so they are unlikely to include the true maximum size. A recent paper shows that the subgenus within Gymnotus called Tigrinus is made up of 7 species that all have an adult body size of less than 250 mm (about 10 inches). I think that of these, G. coropinae (162 mm max.) is the smallest species for which there is a decent amount of data.
Unfortunately though, out of the 40+ species of Gymnotus, I have only ever definitively seen 3 in the aquarium trade: G. carapo, G. tigre, and G. javari. Of these, javari is the smallest as Fishman Dave said.