If you run procurement at a federal prime, or you own Tier-2 reporting for a Fortune 500 buyer, the ground shifted under you in 2025. Executive Order 11246, the affirmative-action mandate that anchored federal contractor programs since 1965, was rescinded on January 21, 2025. The grace period to wind down those affirmative-action plans closed April 21, 2025, and the implementing regulations were formally pulled later that summer. A lot of corporate programs quietly renamed themselves or went dark.
Here is the distinction that matters. The rollback hit voluntary race- and gender-conscious programs and the OFCCP affirmative-action regime. It did not touch the statutory small-business subcontracting framework. If you hold a federal contract above the threshold, FAR 52.219-9 still requires a subcontracting plan, the eSRS reports are still due, and the government-wide goals still stand: 23% of prime dollars to small business, 5% to women-owned, 5% to service-disabled veteran-owned, 3% to HUBZone, 5% to small disadvantaged. Those are law, not policy preference.
So the work continues. What changes is the framing and the rigor. A program built on "diversity" as a slogan is exposed. A program built on compliance obligations, supplier-base resilience, and measurable economic impact is defensible and worth the budget. Here is how to build that program in 2026.
Start with a charter that names the real driverWrite a one-page charter before you do anything else. It should state, in plain terms, why the program exists. For a federal prime, the answer is concrete: you have subcontracting-plan obligations under FAR 52.219-9 and 19.7, your eSRS performance is visible to every contracting officer who evaluates your next bid, and missed goals invite a finding of failure to make a good-faith effort. For a commercial buyer, the driver is supply-base depth, competition on price and lead time, and the economic-impact story your largest customers and your board still ask for.
Name an executive sponsor and the cross-functional owners: category managers, the small-business liaison officer, legal, and finance. Drop the word "diversity" from the charter's mission line if it is doing nothing but signaling. Keep it as a precise category term where you mean a specific certified group. Lead with what the program delivers. A defensible charter reads like a business case, not a values statement.
Set goals you can actually source againstFederal primes inherit their numbers. Your subcontracting plan commits you to specific percentages negotiated into the contract, and those flow from the government-wide targets. Two recent changes are worth re-checking against your plan template. The SDVOSB prime goal was raised from 3% to 5% by the National Defense Authorization Act for fiscal year 2024. The small disadvantaged business goal returned to its 5% statutory level after the rescission of Executive Order 14091, which had pushed it higher by executive action.
Commercial buyers set their own goals, and 2026 is the year to make them outcome-based rather than headcount-based. Spend with certified small and diverse suppliers is the floor. The number that survives scrutiny is economic impact: jobs supported, local tax base, second-tier spend your suppliers generate. If your program reports to a customer's Tier-2 requirement, align your categories to what they actually collect so your data rolls up cleanly.
Build a clean data baseline before you chase the numberYou cannot manage spend you cannot see. Pull twelve months of supplier spend and match each vendor to a verified certification status. This is where most programs leak credibility, because they count self-reported status that no longer holds up.
The self-certification era is closing. As of the December 22, 2024 deadline, a service-disabled veteran-owned firm has to be certified through SBA's VetCert program to count toward SDVOSB goals on federal contracts and subcontracts. Self-certification for that category is gone. The 8(a), WOSB, EDWOSB, and HUBZone programs run through SBA's certification system at certifications.sba.gov, and certified status appears in the Dynamic Small Business Search (DSBS). Small disadvantaged business status for the SDB goal is still represented in SAM.gov rather than issued as a standalone SBA certification, so treat an SDB claim as a representation to verify, not a certificate to file.
For each supplier, record the certification type, the certifying body, the certificate number, and the expiration date. Stale certificates are the single most common audit finding. Set a recertification tracker now.
Source with intent, not luckA goal without a sourcing pipeline is a press release. Once your baseline shows the gaps, go find qualified suppliers in those categories.
For federal subcontracting, DSBS is your primary market-research tool. Filter by NAICS, set-aside status, and geography to build a bidder list of certified small businesses. SBA's SUBNet was the traditional board for posting subcontracting opportunities, though its new-posting function has been limited, so pair it with DSBS, agency subcontracting directories, and SAM.gov. Document the searches. Good-faith-effort defense lives or dies on the paper trail.
For commercial sourcing, you need a single place to find suppliers across the certifying bodies: NMSDC for minority-owned, WBENC for women-owned, NGLCC for LGBTQ-owned, Disability:IN for disability-owned, and NaVOBA for veteran-owned. Our supplier directory lets you search certified small and diverse suppliers by certification, NAICS, and industry in one pass, so you are not running five logins to assemble one bidder list. When a supplier comes back with a certificate you do not recognize, verify the issuer against our certifying body directory before you count the spend.
Track in the system of record, not a spreadsheetFederal primes report through the Electronic Subcontracting Reporting System (eSRS) at esrs.gov. Two reports drive it. The Individual Subcontract Report (ISR) covers a specific contract and its subcontracting-plan progress. The Summary Subcontract Report (SSR) rolls up your activity across an agency. ISRs and SSRs are filed through eSRS, and the SSR is due within 30 days after the end of the government's fiscal year. Acknowledged-and-accepted status from the awarding agency is what counts; a submitted-but-rejected report is a gap.
One threshold update to confirm against your contracts. The subcontracting-plan requirement under FAR 19.702 rose with the October 1, 2025 inflation adjustment. The trigger moved from $750,000 to $900,000, and the construction threshold from $1.5 million to $2 million. Check which version your active contracts cite, because a plan obligation does not disappear when the threshold changes on a contract already underway.
Whatever your tooling, the rule is the same: spend, certification, and expiration live in your system of record, reconciled to AP, not in a side spreadsheet that nobody trusts at audit time.
Report on impact, and report it the same way every quarterThe reporting that earns budget in 2026 leads with outcomes. Spend by certified category, yes. But pair it with the economic-impact story: supplier jobs supported, contract value awarded to firms in your supply chain, growth of suppliers you sourced two years ago. That narrative holds up whether the audience is a contracting officer, a customer's Tier-2 team, or a skeptical board member who read the headlines about programs being cut.
Keep the methodology consistent across quarters so trends mean something. Tie every reported number back to a verifiable source: an eSRS acceptance, a DSBS record, a certificate on file. The programs getting defunded are the ones that cannot show their math. The ones that survive read like the audited part of the annual report.
For the federal side specifically, our deeper walkthrough on how to meet small-business subcontracting goals covers the good-faith-effort documentation that protects you when a number comes in short.
The short versionThe statutory obligations did not change. The framing did, and the bar for rigor went up. Build the charter around compliance and economic impact, set goals you can source against, baseline your data against verified certifications, source with a documented pipeline, track in eSRS or your system of record, and report on impact the same way every quarter. Start with a clean bidder list. Search certified small and diverse suppliers in our directory and build your baseline from there.
