Small Business

Small Business Subcontracting Guide 2025: Requirements & Opportunities

Complete guide to small business subcontracting in government contracts. Learn about subcontracting plans, goals, compliance requirements, and how to find subcontracting opportunities.

BidFinds Government Contracting Team
December 26, 2025
11 min read

Quick Answer: Small Business Subcontracting

Large businesses with federal contracts over $750,000($1.5M for construction) must submit subcontracting plans with goals for small business participation. This creates opportunities for small businesses to work as subcontractors on major government contracts, building experience and past performance.

$750K
Threshold
23%
SB Goal
5%
SDB Goal
eSRS
Reporting

Small Business Subcontracting Overview

The federal government requires large prime contractors to make good faith efforts to subcontract with small businesses. This policy creates significant opportunities for small businesses to participate in major federal contracts.

Why Subcontracting Matters

For Small Businesses

  • • Access to large contract opportunities
  • • Build past performance record
  • • Learn from experienced primes
  • • Establish relationships with agencies

For Prime Contractors

  • • Meet contract requirements
  • • Access specialized capabilities
  • • Improve proposal competitiveness
  • • Build diverse supply chain

When Subcontracting Plans are Required

Contract Thresholds

General Contracts: $750,000+

Contracts exceeding $750,000 require subcontracting plans from other-than-small businesses

Construction Contracts: $1.5 Million+

Construction contracts have a higher threshold of $1.5 million

Who Must Submit Plans

  • Large businesses (other-than-small)
  • Small businesses that subcontract with non-small businesses
  • Small businesses performing work themselves (exempt)

Important: Subcontracting Limitations

Small business set-aside contracts have limitations on subcontracting. Generally, small business primes must perform at least 50% of the work (services) or 15% (supplies) themselves, limiting how much can be subcontracted.

Federal Small Business Goals

The government establishes annual goals for small business participation. These goals flow down to prime contractors through subcontracting requirements.

Current Governmentwide Goals

23%
Small Business
5%
Small Disadvantaged Business
5%
Women-Owned SB
3%
HUBZone SB
3%
Service-Disabled VOSB

How Goals Apply to Subcontracting

Prime contractors must establish their own goals based on:

  • The subcontracting opportunities in the contract
  • Available small business sources
  • Agency-specific targets
  • Geographic and industry considerations

Subcontracting Plan Elements

FAR 19.704 specifies the required elements of a subcontracting plan. These plans must be reviewed and approved by the contracting officer.

Required Plan Elements

1

Dollar Goals

Separate percentage goals for each small business category

2

Total Subcontracting Amount

Estimate of total subcontract dollars

3

Description of Work

Types of supplies and services to be subcontracted

4

Outreach Methods

How the contractor will identify and solicit small business sources

5

Program Administrator

Designated employee responsible for implementing the plan

6

Reporting & Recordkeeping

Procedures for tracking and reporting subcontracting achievements

Finding Subcontracting Opportunities

SBA SubNet

Free database of subcontracting opportunities:

  • Prime contractors post opportunities
  • Search by NAICS, location, keywords
  • Direct contact with primes

Prime Contractor Outreach

Reach out directly to major primes:

  • Check company websites for supplier portals
  • Attend matchmaking events
  • Register in prime databases

Other Resources

PTAC Counseling

Free assistance identifying opportunities

Industry Days

Meet primes before solicitations drop

SAM.gov

Find upcoming contracts and awarded primes

Trade Associations

Industry-specific networking

Compliance & Reporting

Prime contractors must report their subcontracting achievements through the Electronic Subcontracting Reporting System (eSRS).

eSRS Reporting Requirements

Individual Reports (ISR)

  • • Submitted per contract
  • • Due semi-annually
  • • Reports actual vs. planned
  • • Contract-specific goals

Summary Reports (SSR)

  • • Company-wide summary
  • • Due annually
  • • Aggregate achievements
  • • Required for commercial plans

Failure to Comply

Contractors who fail to make good faith efforts may face:

  • Liquidated damages (actual or standard damages)
  • Negative past performance ratings
  • Ineligibility for future contracts

Frequently Asked Questions

Can I be both a prime and subcontractor?

Yes. Many small businesses start as subcontractors to build experience, then pursue prime contracts while continuing to subcontract on other projects. This builds diverse past performance.

Do subcontractors get CPARS ratings?

Not directly from the government. Your performance is with the prime contractor. However, you can ask primes for reference letters and document your work for future proposals.

How do I know if a prime has subcontracting goals?

Large businesses with contracts over the threshold are required to have plans. Check contract award notices on SAM.gov to identify large business primes, then reach out about opportunities.

Do small business certifications matter for subcontracting?

Primes need certified small businesses to meet specific category goals (WOSB, SDVOSB, HUBZone, etc.). Having certifications makes you more valuable as a subcontractor and opens more opportunities.

Find Prime Contract Opportunities

Identify large contracts where primes will need small business subcontractors. BidFinds helps you find opportunities before awards are made.

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