When a large prime wins a big contract, it often promises the government in writing how much of its subcontracting it will place with small and socioeconomic categories of business. Then it asks its suppliers for the data to prove it. If you are a small supplier, that request is coming, and it is simpler than it looks.
This article covers the plan from the supplier's side: when a plan is required, what it commits the prime to, what a prime will ask you for, and what you do not have to do. We are a small reseller, and these are the requests we answer.
The short version
| Question | Answer |
|---|---|
| When is a plan required? | Generally when a contract is expected to exceed $900,000 ($2 million for construction) and has subcontracting possibilities |
| Who must have one? | Other than small businesses |
| Does a small business need its own plan? | No. FAR 52.219-9 does not apply to small business concerns |
| What will a prime ask a supplier for? | UEI, size and socioeconomic status for the NAICS, and the dollars |
| Where are reports filed now? | SAM.gov, not eSRS |
When a plan is required
The threshold is in FAR 19.702. Under paragraph (a)(1), a subcontracting plan is required for a negotiated or sealed bid acquisition expected to exceed $900,000, or $2 million for construction, when subcontracting possibilities exist. A modification that pushes a contract without a plan over those figures can trigger one too. Many websites still show older thresholds, so check the figures on the FAR page rather than a summary.
The exemptions in paragraph (b) matter for a supplier. A plan is not required:
- From small business concerns.
- For personal services contracts.
- For contracts or modifications performed entirely outside the United States and its outlying areas.
- For certain in-scope modifications where the contract does not contain FAR 52.219-8.
The first one is the one that applies to you if you are small.
What the plan commits the prime to
The clause is FAR 52.219-9, Small Business Subcontracting Plan (Jan 2025 on acquisition.gov under FAC 2026-01). The plan has to contain goals, in dollars and as a percentage of planned subcontracting dollars, for these categories: small business, veteran-owned small business, service-disabled veteran-owned small business, HUBZone small business, small disadvantaged business and women-owned small business.
It also has to state:
- The principal types of supplies and services to be subcontracted, and how the goals were developed.
- How potential sources were identified.
- Whether indirect costs were included in the goals.
- The name and duties of the person who runs the program.
- The efforts to give small businesses an equitable chance to compete.
- The records kept to show compliance.
And it carries assurances. The prime agrees to insert the Utilization of Small Business Concerns clause in subcontracts that offer further subcontracting, to require subcontractors above the threshold (other than small businesses) to adopt their own plans, to submit periodic reports, to not prohibit subcontractors from discussing payment or utilization with the contracting officer, to pay small subcontractors on time, and to make good-faith efforts to use the small businesses named in its proposal.
A prime that writes a plan cannot meet it without supplier data. That is why you get asked.
What a prime will ask you for
The requests tend to be the same few items. Have them ready.
- Your UEI and CAGE code. The prime reports against your SAM identity. Make sure both match your registration.
- Your size and socioeconomic status for the relevant NAICS code. A prime counts your dollars in the category you hold. Size is measured against a NAICS code, so state which code the work falls under and what your SAM record represents for it.
- The dollars. What the prime paid you, by period and by contract, so it can add them into its report. If you invoice by contract, that is usually easy. If your invoices do not name the prime's contract, expect a follow-up question.
- Your legal name and address as they appear in SAM. Mismatches with your quote, W-9 or invoice are where reporting errors start.
- Confirmation when something changes. A new size determination, a lapsed registration, a changed status.
- Sometimes a certification or a representation form. Answer from your SAM record. A certificate PDF is a record of one date, not what the government sees today.
We cover what a supplier should document about its status in minority-owned supplier documentation for primes, and the broader file a prime should collect in what a prime should require of a small supplier.
What a small supplier does not have to do
The common mistake on the supplier side is to think the plan is the supplier's job.
- You do not write a plan. FAR 52.219-9 does not apply to small business concerns, and 19.702(b) exempts them.
- You generally do not file the reports. Primes with plans file Individual Subcontract Reports and Summary Subcontract Reports. First-tier subcontractors can file in some cases, and the conditions are on SAM.gov's page for it, so read the subcontract if a prime asks you to report something.
- You do not owe a prime goals. The goals are the prime's. Your obligation is accurate data and the flow-downs your subcontract names.
If a purchase order asks a small supplier to adopt a subcontracting plan, that is a question for the prime, because the clause carves small businesses out. Ask which clause requires it. We walk through how to check flow-downs in flow-down clauses for suppliers.
Where the reports go now
The FAR text of 52.219-9 still tells the contractor to submit reports in eSRS at esrs.gov. That system was retired in February 2026, and subcontracting reports moved to SAM.gov. The practical effect for a supplier is that the record the government sees is your SAM registration, so keep it current. The details, with links to the SAM.gov announcement, are in eSRS is retired: subcontracting reports now live in SAM.gov.
Direct dollars and the second tier
A subcontracting plan counts what the prime pays its direct suppliers. Some primes also track what their suppliers pay downstream, which is often called second-tier or indirect spend. That is a program choice or a contract requirement, not the same as a plan goal. If a prime asks you for your own downstream spend, ask what it is for and which contract term requires it. We unpack the difference in tier 2 supplier diversity spend.
Check the agency's deviation
The FAR is in the middle of the Revolutionary FAR Overhaul. Agencies are issuing class deviations that rewrite parts of it, and Part 19 is one of them. On the RFO Part 19 materials on acquisition.gov, the subcontracting plan text sits in a renumbered section (19.109) with the same $900,000 and $2 million figures, but the section numbers and clause text in your contract may follow your agency's deviation rather than the page described here. Before you rely on a threshold, a section number or a clause date, look at the version your prime contract cites and at your agency's deviation. Where the FAR and a deviation differ, the contract decides.
How Lunula Supply handles it
We are a small, minority-owned, SAM-registered supplier and reseller in Chicago (CAGE 9GWP3), primary NAICS 423990. We do not carry a subcontracting plan, because the clause does not apply to small businesses. We make it easy for a prime that does.
- We keep our SAM registration current and send representations with the quote or order.
- We answer requests for UEI, status and identifiers without being chased.
- We confirm every order line by line in writing, so the dollars a prime reports match what we invoiced.
- We invoice after delivery through the system the contract names, against the order.
- One contact stays with you from acknowledgment through warranty.
If you are a prime building a supplier base, contact us or see what we supply.
Frequently asked questions
What is the subcontracting plan threshold?
Under FAR 19.702(a)(1), a plan is generally required for negotiated or sealed bid acquisitions expected to exceed $900,000, or $2 million for construction, when subcontracting possibilities exist. Check the current page on acquisition.gov and your agency's deviation, since many sites show older figures.
Does a small business need a subcontracting plan?
No. FAR 52.219-9 says it does not apply to small business concerns, and FAR 19.702(b) exempts them. If a purchase order asks for one, ask the prime which clause requires it.
What information will a prime ask me for?
Your UEI and CAGE code, your size and socioeconomic status for the relevant NAICS code, your legal name and address as they appear in SAM, and the dollars it paid you. Answer from your SAM record and keep it current.
Where do subcontracting reports go now?
They go through SAM.gov. eSRS was retired in February 2026, although the FAR clause text still names it. See our post on the eSRS change for the SAM.gov links.
General information, not legal advice. Figures and clause text were checked against FAR 19.702 and 52.219-9 on acquisition.gov (FAC 2026-01) on the publish date. The FAR is being rewritten and agencies issue class deviations, so verify against your contract. Your contract's terms control.