GSA Subcontracting Plans: When They're Required and What to Include
Small businesses awarded GSA contracts are not required to submit subcontracting plans — the requirement applies to large businesses on contracts (and task orders) exceeding the subcontracting plan threshold. As of 2026, that threshold is $750,000 for most contracts (or $1.5 million for construction). If you are a large business and receive a task order over this threshold under your GSA Schedule, you may be required to submit an acceptable subcontracting plan as a condition of award.
What a Subcontracting Plan Must Include
A compliant subcontracting plan under FAR 52.219-9 must include: a description of your good faith efforts to use small businesses as subcontractors, percentage and dollar goals for small business subcontracting in specific categories (SB, SDB, WOSB, HUBZone, VOSB, SDVOSB), a method for identifying and selecting small business subcontractors, assurances that your subcontractors can comply with equal opportunity requirements, a record-keeping system for tracking subcontracting dollars, and a designated employee responsible for administering the plan.
Setting Realistic Subcontracting Goals
The small business community recommends — and agencies expect — goals that reflect genuine opportunity. Base your goals on historical subcontracting data, the nature of the work being performed, and the available small business vendor base. Extremely low goals (e.g., 0–5% small business subcontracting on a service contract) will draw scrutiny from the contracting officer and agency small business specialist. Realistic goals for professional services typically range from 25–50% small business subcontracting depending on the availability of qualified small business subcontractors in the relevant specialty.
| Category | Federal Goal (FY2025) | Why It Matters |
|---|---|---|
| Small Business overall | 23% | Agencies track against these targets |
| SDB (including 8(a)) | 15% | Socioeconomic priority |
| WOSB | 5% | Set by statute |
| SDVOSB | 3% | Veterans Affairs and DoD priority |
| HUBZone | 3% | Economic development zones |
Subcontracting Plan Reporting (SF-294 and ISR/SSR)
After contract award, large businesses with subcontracting plans must submit progress reports using the Individual Subcontract Report (ISR) or Summary Subcontract Report (SSR) through the Electronic Subcontracting Reporting System (eSRS). Reports are typically due semi-annually (April 30 and October 30) and at contract completion. Failure to submit reports, miss goals without explanation, or show a pattern of not meeting goals can affect your past performance ratings and future award prospects.