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Prime contractor guide to federal subcontracting compliance

Federal subcontracting compliance has four main steps: plan, source, document, and report. This guide walks a prime contractor through each stage and the FAR references that govern them.

1. Adopt the plan

Your plan sets goal percentages you will be measured against.

Your subcontracting plan (FAR 52.219-9 / FAR 19.704) sets goals by certification category. Treat those percentages as commitments you will be measured against.

2. Source and solicit small businesses

Actively find and contact qualified small businesses in your plan NAICS codes.

Actively find and contact qualified small businesses in the NAICS codes your plan covers. A requirement-driven search saves time compared to manual directory lookups.

3. Document good-faith effort

Keep records of who you contacted and what happened.

When a goal cannot be met, contracting officers expect proof you tried. That means solicitations sent, responses received, and why awards did or did not happen. See good-faith effort documentation.

4. Report through SAM.gov

File ISR and SSR reports through SAM.gov Subcontracting Plan Reporting.

File Individual Subcontract Reports (ISR) and Summary Subcontract Reports (SSR) through SAM.gov Subcontracting Plan Reporting. Clean category data makes filing easier — see ISR & SSR data prep.

Watch limitations on subcontracting

Set-aside contracts limit how much work can go to outside firms.

On set-aside awards, FAR 52.219-14 limits how much work can be subcontracted outside similarly situated entities. Confirm the rules for your contract type with counsel or your contracting officer.

Frequently asked questions

Is subcontracting compliance the same on every contract?

No. Requirements vary by contract type, dollar value, and whether the award is a set-aside. Always confirm the specific clauses in your contract with your contracting officer.

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