What is the threshold for requiring a subcontracting plan under 52.219-9?

Contracts expected to exceed $750,000 ($1.5M for construction) require a subcontracting plan if there are subcontracting opportunities. The threshold applies to the total contract value, not individual task orders in most cases.

What percentage goals should we set in our subcontracting plan?

Goals must reflect a good faith effort and align with agency-wide small business goals. Review the agency's current annual small business goals (published in their procurement forecast) as a baseline. Goals that are too low will be rejected during negotiations.

What is the eSRS and how often must we report?

The Electronic Subcontracting Reporting System (eSRS.gov) is where you submit your Individual Subcontract Reports (ISR) semi-annually and Summary Subcontract Reports (SSR) annually. Late or missing reports can affect your past performance ratings.

What are the liquidated damages for failing to comply with the subcontracting plan?

Damages equal the actual dollar amount by which you failed to achieve your plan's goals, not a percentage. The contracting officer calculates this based on your final small business subcontracting spend versus committed goals.

High RiskFARSmall Business

52.219-9 — Small Business Subcontracting Plan

Last updated: 2026-04-09

Researched by the BidStride Research Team

What This Clause Requires

Prime contractors above the applicable threshold must submit a subcontracting plan with goals for small, small disadvantaged, women-owned, HUBZone, SDVOSB, and VOSB subcontracting.

Official Regulation Text

See 48 CFR 52.219-9 for the full regulatory text. This clause requires contractors with contracts over $750,000 ($1.5M for construction) to submit a subcontracting plan establishing percentage goals for six categories of small business subcontracting.
Source: eCFR, 48 CFR 52.219-9

Compliance Checklist

Submit a subcontracting plan with percentage goals by small business category
Plan must be approved before contract award
Submit ISR (Individual Subcontract Report) semi-annually via eSRS
Submit SSR (Summary Subcontract Report) annually
Failure to comply subjects contractor to liquidated damages

Flow-Down to Subcontractors

No flow-down required

This clause applies only to the prime contract and does not need to be flowed down to subcontractors.

52.219-8Utilization of Small Business Concerns

Frequently Asked Questions

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This summary is for informational purposes only and reflects the BidStride Research Team's plain-English interpretation of the regulation. It is not legal advice and does not constitute an attorney-client relationship. Always consult the official Federal Acquisition Regulation (FAR) or Defense Federal Acquisition Regulation Supplement (DFARS) text and qualified legal counsel for compliance decisions.