FAR 52.219‑9 Explained: What Primes Must Do in 2026
- Ricardo Burrage
- Nov 19, 2025
- 2 min read
Introduction
If you’re a prime contractor on a federal contract exceeding $750,000 (or $1.5M for construction), FAR 52.219‑9 isn’t optional—it’s mandatory. This clause governs your Small Business Subcontracting Plan (SBSP), including HUBZone participation goals, reporting obligations, and compliance standards. Missing these requirements can lead to CPARS downgrades, audit findings, and jeopardizing future awards.
In this guide, we’ll break down what FAR 52.219‑9 requires, why HUBZone goals matter, and how to stay compliant in 2025.
What Is FAR 52.219‑9?
FAR 52.219‑9 is the Federal Acquisition Regulation clause that requires large prime contractors to create and maintain a Small Business Subcontracting Plan when awarded contracts above certain thresholds:
$750,000 for supplies and services
$1.5 million for construction
The plan must outline how you will subcontract work to small businesses, including specific socio-economic categories:
HUBZone Small Businesses
Women-Owned Small Businesses (WOSB)
Service-Disabled Veteran-Owned Small Businesses (SDVOSB)
Small Disadvantaged Businesses (SDB/8(a))
Key obligations under FAR 52.219‑9:
Submit a compliant subcontracting plan before award
Make good-faith efforts to meet stated goals
Report semi-annually in eSRS (Electronic Subcontracting Reporting System)
Flow down subcontracting requirements to large subs
Key Elements of a Compliant Subcontracting Plan
Your SBSP must include:
Goals by Category:
HUBZone: 3%
WOSB: 5%
SDVOSB: 3%
SDB/8(a): 5%
Description of Outreach: How you’ll identify and engage small businesses
Reporting Commitments: eSRS semi-annual submissions
Flow-Down Clauses: Ensure subs comply with FAR requirements
Why HUBZone Goals Matter
HUBZone participation is often the hardest metric to hit. Here’s why:
Limited pool of HUBZone-certified firms
Residency requirement (35%) makes staffing complex
Agencies track HUBZone utilization closely—failure impacts CPARS
Primes with strong HUBZone performance gain competitive advantage in future bids
Common Pitfalls & How to Avoid Them
Late eSRS submissions → triggers compliance flags
Generic outreach logs → fail audits
Underestimating HUBZone sourcing → missed goals
Pro Tip: Document every outreach effort and maintain a HUBZone partner pipeline.
Action Steps for 2025 Compliance
Review FAR 52.219‑9 clause in your contract
Set realistic HUBZone targets early
Document outreach and subcontractor engagement
Use templates and calculators to track progress
Compliance Example: HUBZone Goal Calculation
Imagine a $10M services contract with a 3% HUBZone goal:
Required HUBZone subcontracting = $300,000
If you only subcontract $150,000, you’re at 50% of goal → CPARS risk
Solution: Use our HUBZone Goal Calculator to model scenarios and avoid shortfalls.
FAQ Section (Schema Ready)
Q1: What is FAR 52.219‑9?
It’s the FAR clause requiring subcontracting plans for large primes on contracts above $750K (services) or $1.5M (construction).
Q2: What are HUBZone subcontracting goals?
Typically 3% of subcontracted dollars, but check your contract for specifics.
Q3: How do I submit eSRS reports?
Log into https://www.esrs.gov, complete the ISR and SSR forms semi-annually, and ensure accuracy.
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