SBA eliminates self-certification for WOSB / EDWOSB set-asides
Citation: 85 Fed. Reg. 27650 (May 11, 2020); 13 CFR § 127.300 et seq. Primary source ↗
Full explanation
From the WOSB program's launch in 2011 until October 2020, firms could **self-certify** as Women-Owned Small Business (WOSB) or Economically Disadvantaged Women-Owned Small Business (EDWOSB) by registering on SAM.gov and submitting required documents to the WOSB Repository. The self-certification framework was widely criticized as enabling abuse — firms could claim WOSB status with limited verification and pursue set-aside contracts on that basis.
The 2020 rule eliminated self-certification. Effective October 15, 2020, all WOSB and EDWOSB participants must obtain certification through one of two pathways:
1. **SBA Certify** (certify.sba.gov) — the SBA's centralized federal certification portal that also handles 8(a), HUBZone, and SDVOSB. Free.
2. **Third-party certification** — through an SBA-approved third-party certifier such as the National Women Business Owners Corporation (NWBOC), the U.S. Women's Chamber of Commerce, or specific state procurement agencies. Some carry fees.
**WBENC certification specifically.** WBENC's WBE certification is recognized as one of the SBA-approved third-party WOSB pathways — meaning firms with WBENC WBE status can use that to satisfy the federal WOSB certification requirement, with additional verification of the 'small business' size standard.
**EDWOSB has additional economic-disadvantage requirements.** Personal net worth ≤$850K, AGI ≤$400K (3-year average), total assets ≤$6.5M — same caps as 8(a). EDWOSB-certified firms qualify for both WOSB and EDWOSB set-asides; WOSB-only certified firms qualify for WOSB set-asides only.
What this means for diverse contractors
**For self-certified WOSB/EDWOSB firms still on SAM.gov:** Your self-certification is no longer valid for federal set-aside purposes. Apply through SBA Certify (free) or one of the approved third-party certifiers to maintain set-aside eligibility.
**For new WOSB applicants:** SBA Certify is the simplest path — free, online, ~60-90 day processing. If you already hold WBENC WBE, the third-party pathway through WBENC may consolidate your corporate-side and federal-side certification into a single ongoing process.
**For EDWOSB applicants:** Apply for both WOSB and EDWOSB at the same time through SBA Certify. The applications share most documentation; EDWOSB adds the personal financial disclosure for the economic-disadvantage test.
**Set-aside contract eligibility:** WOSB set-asides apply only in NAICS codes the SBA has designated as under-represented for women-owned businesses. EDWOSB set-asides apply in the broader 'substantially under-represented' designated NAICS list. Check the SBA's WOSB-designated NAICS list before assuming your industry qualifies for set-asides.
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