How Primes Count WOSB Subcontracts Toward Their Goals

Key points

Codified FAR and the RFO deviation, side by side

Two versions of the small business subcontracting rules are in use. The codified FAR is FAC 2026-01, effective March 13, 2026. The Revolutionary FAR Overhaul (RFO) model deviation text is what agencies adopt through class deviations.

Question	Codified FAR (FAC 2026-01)	RFO deviation text
Is a subcontracting plan required?	Above $900,000 ($2 million for construction) with subcontracting possibilities, from offerors that are not small (FAR 19.702(a)(1), (b)(1))	Same thresholds ("construction of any public facility") and the same small business exemption (FAR 19.109(a)(1), (b)(1))
How many goal lines?	Six: small business, veteran-owned, service-disabled veteran-owned, HUBZone, small disadvantaged and women-owned small business (FAR 19.704(a)(1))	The same six (52.219-9(d)(1))
What makes a WOSB subcontract count?	The subcontractor's written or SAM representation, unless you have reason to question it (FAR 19.703(a)(2))	SBA certification (52.219-9(c)(2)(v))
How do you check?	Review the representation	Check SAM or SBA's Small Business Search (52.219-8(e)(5))
Where do you report?	eSRS (52.219-9(d)(10)(iv))	Subcontracting Plan Reporting (SPR) at SAM.gov (52.219-9(d)(10)(iv))

Goal lines

The six goal lines in a subcontracting plan

FAR 19.704(a)(1) requires separate percentage goals for six groups of subcontractors. Paragraph (d)(1) of the clause at 52.219-9 says the same in both versions.

Goal line	Notes
Small business	Includes Alaska Native Corporations and Indian tribes
Veteran-owned small business (VOSB)
Service-disabled veteran-owned small business (SDVOSB)
HUBZone small business
Small disadvantaged business (SDB)	Includes Alaska Native Corporations and Indian tribes
Women-owned small business (WOSB)	There is no separate EDWOSB line. An economically disadvantaged WOSB counts here

A women-owned small business is by definition a small business concern (the definition in the clause at 52.219-8 begins "a small business concern"), so the same subcontract dollars also count in your small business line.

Why the goals exist. The Small Business Act sets a governmentwide goal for participation by women-owned small businesses of not less than 5 percent of the total value of all prime contract and subcontract awards for each fiscal year (15 U.S.C. 644(g)(1)(A)(v)). The goal covers subcontract awards as well as prime contract awards.

Thresholds

When a prime needs a subcontracting plan

Value and type. A negotiated or sealed-bid contract expected to exceed $900,000, or $2 million for construction, that has subcontracting possibilities (FAR 19.702(a)(1)(i) and (ii); FAR 19.109(a)(1)(i) and (ii) under the RFO deviation).
Not required from small business concerns, for personal services contracts, or for contracts performed entirely outside the United States and its outlying areas (FAR 19.702(b); FAR 19.109(b) under the RFO deviation). The codified FAR also exempts in-scope modifications to a contract that does not contain the clause at 52.219-8 (FAR 19.702(b)(4)).
Above the simplified acquisition threshold ($350,000, FAR 2.101), every contractor agrees that small business, VOSB, SDVOSB, HUBZone, SDB and WOSB concerns will have the maximum practicable opportunity to participate in contract performance (FAR 19.702).
Flow-down. Your plan must assure that you include the clause at 52.219-8 in all subcontracts that offer further subcontracting opportunities, and that you require subcontractors other than small businesses that receive subcontracts above $900,000 ($2 million for construction) to adopt their own plan (FAR 19.704(a)(9)).

If you are a small business prime, you do not need a plan. On a small business set-aside above the simplified acquisition threshold, and on any 8(a), HUBZone, SDVOSB or WOSB set-aside or sole-source award, the contracting officer inserts the limitations on subcontracting clause at FAR 52.219-14 instead (FAR 19.507(e)(1)). Our WOSB and EDWOSB certification page explains how that clause treats a similarly situated subcontractor.

Eligibility

How a WOSB subcontractor's status is established

Under the FAR as codified

Unless you have reason to question it, you may accept a subcontractor's written representation of its size and socioeconomic status, including women-owned small business status, if the subcontractor represents that it is current, accurate and complete as of the date of its offer. You may instead accept its representation in SAM if it is registered there and represents the same (FAR 19.703(a)(2)(i) and (ii)).

You may not require a subcontractor to use SAM to represent its size or status (FAR 19.703(a)(2)(iii)).
A prime acting in good faith is not liable for a subcontractor's misrepresentation of its size or status (FAR 19.703(a)(2)(iv)).
Size is judged against the size standard for the NAICS code that you determine best describes what the subcontract buys (FAR 19.703(a)(1)). That code can differ from the subcontractor's primary NAICS code.

The codified definition of a women-owned small business concern in the clause at 52.219-8 (Jan 2025) is about ownership and control by women. It has no certification element.

Under the RFO deviation text

The RFO model text of 52.219-9 keeps self-representation only for small business and SDB status (paragraphs (c)(2)(i) and (ii)). For the other lines it says: "In order to be eligible as a VOSB, SDVOSB, HUBZone small business, or WOSB concern, subcontractor under a subcontracting plan, the small business must be certified by the Small Business Administration (SBA) as that socioeconomic status" (52.219-9(c)(2)(v), RFO deviation text).

The RFO text of 52.219-8 matches it:

Its definition of a WOSB concern adds a third element: certified by SBA or an approved third-party certifier in accordance with 13 CFR 127.300, and designated by SBA as a WOSB concern in the Small Business Search and SAM.
Paragraph (e)(5) says the contractor "shall confirm that a subcontractor representing itself as a HUBZone small business concern, VOSB, SDVOSB, or WOSB concern is certified by SBA by checking SAM or SBS."

What this means in practice. Under the RFO text, a women-owned firm that has only self-certified does not count in your WOSB line, and neither does a firm whose SBA application is still pending. A firm SBA has certified as a WOSB or EDWOSB does; the codified FAR says an EDWOSB "automatically qualifies as a women-owned small business (WOSB) concern eligible under the WOSB Program" (FAR 2.101). Either firm still counts in your small business line if it is small under the NAICS code you assign to the subcontract.

Which version is in your contract

Look at the 52.219-9 clause in your prime contract. The codified clause carries a month and year in its title, currently "Small Business Subcontracting Plan (Jan 2025)"; an earlier date such as (Sep 2023) is still the codified text. The RFO model clause carries a deviation date in its title.

Agencies adopt the RFO text through class deviations. On October 17, 2026, the FAR Overhaul deviation guide (last updated September 28, 2026) listed Part 19 deviations from 31 agencies, including all 15 executive departments. The RFO Part 19 text was issued September 26, 2025 and updated February 20, 2026. The FAR Council's RFO proposed rules published in the Federal Register so far (June 23 and September 18, 2026) cover other FAR parts, including Part 52; none covers Part 19 and none is final. When in doubt, ask your contracting officer which text governs your plan, and keep the answer in the file.

Verification

How to verify a WOSB in SBA's Small Business Search or SAM.gov

Open SBA's Small Business Search at search.certifications.sba.gov. The old Dynamic Small Business Search address, dsbs.sba.gov, now redirects there.
Search by the firm's name, UEI or CAGE code.
On the firm's profile, find the SBA Certifications section and check that the WOSB or EDWOSB certification is active. Note its entrance date and exit date.
Tell SBA certifications apart from self-certifications. A Small Business Search record can also list the firm's own self-certifications, including women-owned small business, under business type and self-certifications. Sthenos's own record lists both. Under the RFO text only the SBA certification counts.
Confirm the firm is small for the NAICS code you will assign to the subcontract (FAR 19.703(a)(1)). The profile's NAICS table shows, code by code, whether the firm is small.
Save a dated copy of what you saw in the subcontract file. Under the RFO text the check itself is required (52.219-8(e)(5)). Under either version, SBA lists "failure to maintain records or otherwise demonstrate procedures adopted to comply with the plan" among its examples of a failure to make a good faith effort (13 CFR 125.3(d)(3)(ii)(D)).

The RFO text accepts a check in either SAM or the Small Business Search (52.219-8(e)(5)), and it points to the Small Business Search for the certification itself: "SBA certifications are in the Small Business Search (SBS) website" (52.219-9(c)(2)(v)).

Sourcing

How prime contractors find WOSB subcontractors for NAICS 541511

Filter SBA's Small Business Search by NAICS code (for example 541511, Custom Computer Programming Services) and by SBA certification, choosing Women-Owned Small Business or Economically Disadvantaged Women-Owned Small Business. Then open each profile and run the checks above.

SBA's rule lists ways to do this market research: online searches via SAM, posting Notices of Sources Sought or Requests for Proposal on SBA's SUB-Net, Business Matchmaking events and pre-bid conferences (13 CFR 125.3(b)(3)(ii)). It also lists, among examples of a failure to make a good faith effort, failing to conduct market research "through all reasonable means including outreach, industry days, or the use of federal database marketing systems such as SBA's Dynamic Small Business Search (DSBS) or SUBNet Systems or any successor federal systems" (13 CFR 125.3(d)(3)(ii)(G)).

Your plan must also describe the method you used to identify potential sources (FAR 19.704(a)(5)). Record which searches you ran and when.

Credit

Which subcontract dollars count

First tier, as a rule. Reported subcontract award data is limited to awards to your immediate next-tier subcontractors, and credit cannot be taken beyond that tier except in the cases the rule lists (13 CFR 125.3(a)(1)(i)).
The single-contract election. Where the goals pertain only to a single contract with one federal agency, you may elect to take credit for small businesses at any tier, and the election must be recorded in the plan (13 CFR 125.3(a)(1)(i)(C)). Lower-tier subcontractors must have their own individual subcontracting plans for their subcontracting to be credited, and you must incorporate their goals in yours.
Commercial and multi-contract plans. Where the goals pertain to more than one contract or more than one agency, credit is for first-tier small business subcontractors only. That restriction applies to all commercial plans (13 CFR 125.3(a)(1)(i)(C)(5)).
Affiliates. Purchases from your own affiliates, or from a joint venture you are part of, are not included in the subcontracting base (13 CFR 125.3(a)(1)(i)(B)).

Reporting

Reporting WOSB achievement

You report achievements on the Individual Subcontract Report (ISR) and the Summary Subcontract Report (SSR), which cover each goal line, including women-owned small business concerns (52.219-9(d)(10)(iv)). Under the codified FAR the ISR is due semi-annually for the periods ending March 31 and September 30, and the SSR annually by October 30 (FAR 19.704(a)(10)(iv)).

The codified clause names the Electronic Subcontracting Reporting System (eSRS) at esrs.gov, which now redirects to SAM.gov (checked October 17, 2026). The RFO text names the system Subcontracting Plan Reporting (SPR), "the electronic subcontracting reporting system at SAM.gov".

Checklist

Common mistakes

Counting a self-certified WOSB under an RFO-deviation plan. Under 52.219-9(c)(2)(v) of the RFO text, only an SBA-certified WOSB counts.
Counting a firm whose certification is pending. Pending is not certified under the RFO text.
Looking for an EDWOSB goal line. There is none. EDWOSB dollars go in the women-owned small business line (FAR 19.704(a)(1)).
Checking size against the wrong NAICS code. Size follows the code you assign to the subcontract (FAR 19.703(a)(1)).
Requiring the subcontractor to represent through SAM. Neither version allows you to require it (FAR 19.703(a)(2)(iii); 52.219-9(c)(2)(iii) in the RFO text).
Counting second-tier dollars on a commercial plan. Credit is first tier only where goals cover more than one contract or agency (13 CFR 125.3(a)(1)(i)(C)(5)).
Forgetting the flow-down. The clause at 52.219-8 goes into subcontracts that offer further subcontracting opportunities (FAR 19.704(a)(9)).
No record of the check. Save the dated Small Business Search result with the subcontract.

For your plan

Where Sthenos fits

Sthenos LLC (Sthenos Technologies) is certified by SBA as a Women-Owned Small Business and an Economically Disadvantaged Women-Owned Small Business, active March 5, 2026 to March 5, 2029. Our UEI is ULUZGKWYCJB7, our CAGE code is 9RX92 and our primary NAICS code is 541511, Custom Computer Programming Services.

SBA's record shows us as small under every one of the 31 NAICS codes on our profile, so a first-tier subcontract to us is eligible for credit in your small business and women-owned small business lines under either version of 52.219-9, provided we are small under the NAICS code you assign to the subcontract and the credit rules in 13 CFR 125.3 are met. We are not HUBZone certified and not certified as veteran-owned or service-disabled veteran-owned. USAspending.gov lists no federal prime awards or reported subawards for our UEI, so this is eligibility, not federal past performance.

Check our record in SBA's Small Business Search.

Request a Free 30 Minute Consultation→ WOSB and EDWOSB certification details View our capability statement

The consultation request goes to our government IT services team, which works with agencies and primes.

FAQ

Frequently asked questions

Does an EDWOSB count separately from a WOSB in a subcontracting plan?

No. A subcontracting plan has six goal lines under FAR 19.704(a)(1), and none is for EDWOSBs. An economically disadvantaged women-owned small business counts in the women-owned small business line.

Can a prime accept a subcontractor's self-certification as a women-owned small business?

Under the FAR as codified, yes, unless the prime has reason to question it (FAR 19.703(a)(2)). Under the Revolutionary FAR Overhaul deviation text of 52.219-9, no: a WOSB subcontractor must be certified by SBA to count under a subcontracting plan (52.219-9(c)(2)(v)).

How does a prime verify that a subcontractor is SBA-certified as a WOSB?

Search the firm by name, UEI or CAGE code in SBA's Small Business Search at search.certifications.sba.gov, or check SAM.gov, confirm that the WOSB or EDWOSB entry is an SBA certification with an active status, and save a dated copy. The RFO text of 52.219-8(e)(5) requires this check.

How do prime contractors find WOSB subcontractors for NAICS 541511?

Filter SBA's Small Business Search by NAICS code 541511 and by the WOSB or EDWOSB SBA certification, then open each profile to confirm that the certification is active and that the firm is small under the NAICS code you will assign to the subcontract. SBA's rule also names searches in SAM, notices on SBA's SUB-Net, Business Matchmaking events and pre-bid conferences as ways to do this market research (13 CFR 125.3(b)(3)(ii)).

When does a prime contractor need a small business subcontracting plan?

When a negotiated or sealed-bid contract is expected to exceed $900,000, or $2 million for construction, and has subcontracting possibilities, unless the offeror is a small business or another exemption applies (FAR 19.702; FAR 19.109 under the RFO deviation).

Do second-tier subcontracts count toward a prime's WOSB goal?

As a rule, credit is limited to first-tier subcontracts (13 CFR 125.3(a)(1)(i)). On a plan for a single contract with one agency, the prime may elect to count lower tiers under the conditions in 13 CFR 125.3(a)(1)(i)(C). Commercial and multi-contract plans count first tier only.

What is the governmentwide goal for women-owned small businesses?

Not less than 5 percent of the total value of all prime contract and subcontract awards for each fiscal year (15 U.S.C. 644(g)(1)(A)(v)).

Sources

Every regulation and statute cited on this page was read at source on October 17, 2026. This guide explains the rules; it is not legal advice, and your contracting officer decides which text governs your contract.

Published by Sthenos Technologies, an SBA-certified WOSB and EDWOSB software firm (UEI ULUZGKWYCJB7, CAGE 9RX92).

Counting WOSB and EDWOSB Subcontracts Toward Your Plan