Two federal rules have almost identical names and are constantly confused — subcontracting plans (FAR 52.219-9) and the limitations on subcontracting (FAR 52.219-14). They apply to different contractors and do opposite things. Mixing them up leads to real compliance mistakes. Here’s the clean distinction.

Limitations on Subcontracting (FAR 52.219-14)

  • Who: the prime on a set-aside (8(a), WOSB, HUBZone, SDVOSB, or small business set-aside).
  • What it does: caps how much of the award you can pass to firms that aren’t similarly situated — i.e., it forces the small-business prime to self-perform a minimum share (e.g. at least 50% of services/supplies). It exists so a small business actually does the work, not just fronts it.
  • Direction: keeps work in (you must perform a floor amount yourself).

This is the rule that interacts with your teaming and pricing on every set-aside — covered in depth in our limitations on subcontracting guide.

Small Business Subcontracting Plan (FAR 52.219-9)

  • Who: generally a large business winning a sizable contract above a threshold (small businesses are exempt — you don’t write one). Plans apply to non-small primes.
  • What it does: requires the large prime to plan and report on how much of its subcontracting dollars go to small businesses — including the various socioeconomic categories — often with goals.
  • Direction: pushes work out (a big prime committing to flow dollars down to small firms).

Why the distinction matters

  • If you’re a small-business prime on a set-aside: 52.219-14 is your concern — self-perform the required share, and use similarly situated partners so their work doesn’t count against the cap. You are not writing a 52.219-9 plan.
  • If you’re a small business chasing subcontracts: 52.219-9 is your friend — large primes have goals and reporting obligations to subcontract to firms like you. That’s leverage when you approach them for teaming and a path to build past performance.
  • If you grow past small: you may start owing a 52.219-9 plan on your larger awards — confirm your status with the size standards.

The bottom line

Same family, opposite jobs: 52.219-14 makes a small-business set-aside prime do the work itself; 52.219-9 makes a large prime subcontract dollars to small businesses. Know which one applies to you on each contract — your obligations (and your opportunities) depend on it.

This article is general information, not legal advice. FAR requirements and thresholds change; verify the current clauses before relying on them.