FAR 19.15: WOSB / EDWOSB Rule of Two for set-aside decisions
Citation: FAR Subpart 19.15 Primary source ↗
Full explanation
The Federal Acquisition Regulation (FAR) Subpart 19.15 implements the WOSB and EDWOSB Federal Contract Program. It's the operational rulebook contracting officers reference when deciding whether to set aside a procurement for women-owned small business competition.
**The 'Rule of Two' for WOSB:** A contracting officer must set aside a contract for WOSB or EDWOSB when:
1. The acquisition is in a NAICS code designated by SBA as under-represented (for WOSB) or substantially under-represented (for EDWOSB) for women-owned businesses; and
2. There is reasonable expectation that at least two responsible WOSB or EDWOSB concerns will submit offers; and
3. The contract price will not exceed fair market value.
If all three conditions are met, the set-aside is mandatory under FAR 19.1505. If the set-aside fails to attract two qualifying bidders at fair market price, the procurement may be opened to broader competition (full and open or another set-aside type).
**Sole-source authority:** WOSB and EDWOSB also include sole-source authority for contracts up to $4.5M (services) or $7M (manufacturing), subject to specific certification and price-reasonableness requirements.
**The WOSB-designated NAICS list:** SBA periodically refreshes the list of NAICS codes designated as under-represented or substantially under-represented for women-owned businesses. The current list covers most professional services NAICS, many construction NAICS, and a meaningful slice of manufacturing — but excludes large categories like wholesale trade, retail trade, and most accommodation/food services.
**Certification requirements:** Effective October 15, 2020, all WOSB and EDWOSB participants must hold SBA-issued or SBA-approved third-party certification (self-certification on SAM.gov is no longer sufficient). See related entry on the elimination of WOSB self-certification.
What this means for diverse contractors
**For certified WOSB / EDWOSB firms:** Track contract opportunities in your designated NAICS codes. Federal contracting officers are required to consider WOSB set-asides under the Rule of Two — but won't always do so proactively. If you spot a procurement in a designated NAICS where you have reasonable competitors, request that the contracting officer evaluate it for WOSB set-aside under FAR 19.1505.
**For sole-source WOSB / EDWOSB pursuits:** Identify a contracting officer with a specific procurement need that fits your capability, and propose a sole-source award under FAR 19.15. Sole-source dollar thresholds are $4.5M for services and $7M for manufacturing.
**For NAICS not on the WOSB designated list:** WOSB set-asides are not available in your industry. You may still qualify for other set-aside programs (8(a), HUBZone, SDVOSB) depending on your other characteristics, or for the broader Small Business set-aside framework.
**EDWOSB advantage:** EDWOSB-certified firms can compete in BOTH WOSB and EDWOSB set-asides. EDWOSB designation requires additional economic-disadvantage tests (PNW ≤$850K, AGI ≤$400K, assets ≤$6.5M) but the broader contracting access usually justifies the additional certification effort.
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