- Approved subcontracting plan and any modifications by PIID.
- List of certified small businesses considered for each requirement scope.
- Dated outreach or solicitation records (email, platform logs, industry day notes).
- Subcontract award data with UEIs aligned to SAM.gov.
- Explanations when selected subs do not match plan category targets.
FAR 52.219-9 recordkeeping for subcontracting plan execution
FAR 52.219-9 requires prime contractors to make good-faith efforts to use small businesses as subcontractors and to maintain records that support plan performance. Recordkeeping is not a separate filing — it is the evidence behind ISR/SSR data and contracting officer questions.
Records contracting officers expect
Organizing records by PIID
Subcontracting plans are contract-specific. Storing outreach and match data at the requirement (PIID + NAICS + category) level makes ISR/SSR reconciliation faster than portfolio-wide spreadsheets. SamMatch ties matches and mailbox outreach to each requirement automatically.
Retention and audit readiness
Follow your contract records schedule and internal policy. Export or archive good-faith effort summaries periodically — see sample GFE report and good-faith effort documentation.
Related resources
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