Procurement

Contract Bundling Guide 2025: Small Business Impacts & Protections

Complete guide to contract bundling in government contracting. Learn what bundling is, how it affects small businesses, bundling restrictions, and strategies for competing on bundled contracts.

BidFinds Government Contracting Team
December 26, 2025
9 min read

Quick Answer: Contract Bundling

Contract bundling combines multiple smaller contracts into one larger contract, which can reduce opportunities for small businesses. Federal law (FAR 7.107) restricts bundling and requires agencies to justify when bundling is necessary. Small businesses can compete through teaming or joint ventures.

FAR 7.107
Bundling Rules
SBA
Review Required
Teaming
Key Strategy

What is Contract Bundling?

Contract bundling occurs when an agency consolidates two or more requirements previously performed under separate smaller contracts into a single, larger contract that is unlikely to be suitable for small business.

Examples of Bundling

  • Combining IT support contracts from multiple locations into one national contract
  • Merging separate facilities maintenance contracts into one enterprise-wide contract
  • Consolidating regional security services into a single contract

Bundling vs Consolidation

Key Differences

Contract Bundling

  • • Combines contracts previously held by small business
  • • New contract unsuitable for small business
  • • Stricter justification requirements
  • • Requires SBA review

Contract Consolidation

  • • Combines requirements regardless of prior holders
  • • May or may not affect small business
  • • Less strict requirements
  • • Market research required

Bundling Restrictions

FAR 7.107 places significant restrictions on bundling to protect small business opportunities.

Agency Requirements

Market Research

Agencies must conduct market research to determine if bundling is necessary

Measurable Benefits

Must demonstrate substantially greater benefits than alternatives

SBA Notification

SBA must be notified and can challenge bundling decisions

Documentation

Written justification required in the contract file

Substantially Greater Benefits

Bundling is only justified if benefits (cost savings, quality, acquisition cycle time, technical capability) substantially exceed what would be achieved through smaller contracts.

Strategies for Small Businesses

Competing on Bundled Contracts

Form Joint Ventures

Partner with other small businesses to compete as a team

Teaming Arrangements

Create prime-sub relationships to meet capacity requirements

Mentor-Protégé Agreements

Partner with large businesses under mentor-protégé programs

Challenge Improper Bundling

Contact SBA's Procurement Center Representative if bundling is unjustified

Subcontracting Opportunities

Even if you can't win as prime, bundled contracts often have significant small business subcontracting requirements. Position yourself as a subcontractor to the winning prime.

Frequently Asked Questions

How do I challenge bundling?

Contact the SBA's Procurement Center Representative (PCR) for your area. They can review the bundling decision and challenge it if not properly justified.

Can bundled contracts be set aside for small business?

Yes, if market research shows that small businesses (including through teaming or joint ventures) can perform the work. Agencies must consider set-asides before bundling.

What dollar threshold triggers bundling rules?

Bundling restrictions apply when the consolidated contract exceeds the simplified acquisition threshold ($250,000) and combines requirements previously suitable for small business.

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