If you run subcontracts at a federal prime, you already know the obligation. Win a contract over the subcontracting-plan threshold and FAR 52.219-9 puts a small business subcontracting plan in your file, with goals for small business, SDVOSB, HUBZone, SDB, and WOSB participation. Then you have to actually source the firms, hit the goals, and report it through eSRS twice a year. The plan is the easy part. Finding qualified small subcontractors and documenting that you tried is the work.
SBA SUBNet, the Subcontracting Network, is one of the tools the government built for exactly this. It's worth knowing what it does, what it doesn't, and what to put next to it so your outreach holds up under a contracting officer's review.
What SUBNet isSUBNet is a free SBA-run posting board. Large prime contractors that carry a subcontracting plan post current subcontracting opportunities, sources-sought notices, solicitations, and statements of work, and small businesses browse and search the listings to find work. SBA runs it at sba.gov as part of the prime and subcontracting guidance, and questions route to subcontracting@sba.gov.
The pitch is straightforward. A prime with a goal to meet posts the opportunity publicly. Small firms that match the scope find it and respond. The prime documents that it broadcast the opportunity to the small business community, which is the kind of evidence you want when a contracting officer reviews your good-faith effort to meet the plan.
That evidence matters more than the listing volume. Contracting officers reviewing a subcontracting plan under FAR 19.7 want to see that you made a real effort to find small and socioeconomic firms, not just that you hit a number. A dated SUBNet posting, alongside DSBS searches and direct outreach, is part of the paper trail that shows you tried. SBA also publishes a Directory of Federal Government Prime Contractors with Subcontracting Plans, which small firms use to find primes like you; being listed and reachable is part of the same good-faith picture.
Small businesses searching SUBNet can filter by state and keyword and sort the listing by description, closing date, performance start date, NAICS code, and point of contact. Older versions of the tool also let you search by solicitation number and the legacy SIC code. The point of contact for each notice is the prime's buyer, so a small firm responds to the prime directly, not to SBA.
How a prime posts on SUBNet (and the current catch)The intended flow: a prime with an active subcontracting plan logs in, creates a notice for an upcoming subcontract, attaches the solicitation or statement of work, sets the NAICS code, closing date, and point of contact, and publishes it for small firms to find.
Here's the catch you need to know before you build a process around it. As of mid-2026, SBA's own SUBNet page carries a notice that "the ability to post new subcontracting opportunities is not currently available." The search side still works for existing listings, but primes can't add new solicitations right now. Confirm the current status before you tell a small business liaison officer to route outreach through it. If posting is back, great. If it isn't, you need a backup, and you should be documenting outreach somewhere that doesn't depend on a single SBA tool that goes dark.
That fragility is the practical knock on SUBNet. Even when posting works, participation is uneven, listings can be sparse, and a quiet board is not a reliable sourcing channel on its own. Treat it as one input, not the plan.
Why this matters for your goals and your reportThe federal government is required to direct at least 23% of prime contract dollars to small businesses, with statutory sub-goals of 5% for WOSB, 5% for SDVOSB (raised from 3% by the FY2024 NDAA), 3% for HUBZone, and 5% for SDB. Those numbers flow down. Your subcontracting plan sets goals in the same categories, and your performance gets reported through the Electronic Subcontracting Reporting System.
In eSRS you file the Individual Subcontract Report on each plan, and the Summary Subcontract Report rolls your activity up across an agency. Both feed the government's scorecard. The subcontracting-plan requirement itself kicks in under FAR 19.702: in negotiated acquisitions, an offer expected to exceed $900,000, or $2 million for construction, with subcontracting possibilities, requires an acceptable plan. Those thresholds rose from $750,000 and $1.5 million on October 1, 2025, so if your internal SOPs still cite the old numbers, update them.
When you report a subcontract dollar in a socioeconomic category, the subcontractor's status has to be real, and the rules tightened. SDVOSB self-certification ended on December 22, 2024. To count a subcontract toward an SDVOSB goal now, the firm has to be certified in SBA's VetCert program through certify.sba.gov. Self-certified SDVOSBs no longer count toward agency or prime subcontracting goals. SDB is different: a firm still self-certifies as a small disadvantaged business through its SAM.gov representations, and any 8(a) participant qualifies as an SDB automatically. WOSB and HUBZone are formal certifications you can confirm at certify.sba.gov. If your category counts depend on status, verify the status; don't take a checkbox on a capability statement at face value.
What to pair with SUBNetSUBNet is a posting board, not a vetted vendor database, and it's intermittently down. Pair it with sources that let you search and verify on demand.
- SBA's Dynamic Small Business Search (DSBS). Generated from SAM.gov registrations, DSBS lets you search active small firms by NAICS, location, certification, and keyword. It's where contracting officers do market research, and it's a faster way to build a sourcing list than waiting for primes to post.
- certify.sba.gov and VetCert. Verify 8(a), WOSB/EDWOSB, HUBZone, and SDVOSB status at the source before you record a subcontract dollar in that category. This is the difference between a clean ISR and a finding.
- A searchable supplier directory you control. When you need a minority-, women-, veteran-, or disability-owned firm in a specific NAICS and region, a directory with certification fields beats refreshing a quiet posting board. You can search certified diverse and small suppliers on SupplierDiversity.com, filter to the categories your plan needs, and reach out directly.
- Certifying-body verification. When a supplier claims NMSDC, WBENC, or NGLCC certification, confirm it against the issuing body. Our certifying-body directory maps which organizations issue which certifications so you know where to check.
For the federal side of this work, the cheapest-path-to-federal-contracts walkthrough covers how small firms get registered and certified in the first place, which is useful context when you're coaching a promising subcontractor through the steps that make their dollars countable.
A workflow that holds upPut it together and the routine is simple. Set your category targets from the plan. Build your sourcing list from DSBS and a certified-supplier directory, not from a single board. Post to SUBNet when posting is available, because the public broadcast is good evidence of good-faith effort, and keep your own dated record of outreach for when it isn't. Verify every socioeconomic status at certify.sba.gov or VetCert before you count the dollar. Then file clean ISRs and the SSR in eSRS.
SUBNet earns a place in that routine as a documentation and broadcast tool. It does not earn the role of your primary pipeline. The firms you need are findable today, and the cleanest way to hit a 52.219-9 goal is to search for the supplier, confirm the certification, and award the work, then let SUBNet and eSRS record that you did.
Search certified diverse and small suppliers by NAICS, certification, and location.
