Guide

Can a veteran-owned contractor with no federal past performance still win a federal contract?

Updated October 22, 2026

The neutral rating rule

When an RFP evaluates past performance, the solicitation has to describe how it will evaluate offerors with no relevant performance history. If you have no record of relevant past performance, or no information is available, you may not be rated favorably or unfavorably on that factor. [FAR 15.305, Proposal evaluation] Past performance must be evaluated in negotiated competitive buys expected to exceed the simplified acquisition threshold, unless the contracting officer documents why it is not an appropriate factor. [FAR 15.304, Evaluation factors and significant subfactors]

Your private and commercial jobs count

The solicitation must give offerors a chance to identify past or current contracts for efforts similar to the government requirement, including federal, state, and local government and private work. You may also explain problems on those jobs and the corrective actions you took, and the government must consider that information. [FAR 15.305, Proposal evaluation] Pick the jobs that look most like the work in the solicitation, even if none of them were federal.

Key people, predecessor firms, and subs

The evaluation should take into account past performance of predecessor companies, key personnel who have relevant experience, and subcontractors that will perform major or critical parts of the job, when that information is relevant. [FAR 15.305, Proposal evaluation] If your foreman or project manager ran similar jobs at another company, say so in your proposal.

Joint venture and first-tier sub work

SBA’s rule requires agencies to consider the past performance of small businesses that have been joint venture members or first-tier subcontractors, similarly to prime contract past performance. A small business may use a joint venture’s experience where it does not independently show the past performance needed for award, but it must explain the duties it carried out and cannot claim work done only by its partners. [13 CFR 125.11, Past performance ratings for certain small business concerns] On a prime contract that included a subcontracting plan, a first-tier small business sub may ask the prime for a past performance rating, and the prime must provide it within 15 calendar days of the request. The request must be made within 30 days after the prime’s period of performance ends. [13 CFR 125.11, Past performance ratings for certain small business concerns] The contracting officer must consider that rating even if you have no prime contractor rating in CPARS. [13 CFR 125.11, Past performance ratings for certain small business concerns]

Sealed bids and quotes

In sealed bidding, award goes to the responsible bidder whose conforming bid is most advantageous to the government, considering only price and price-related factors. [FAR 14.101, Elements of sealed bidding] On simplified acquisitions, past performance does not require a formal database and may be based on the contracting officer’s own knowledge, customer surveys and past performance questionnaires, CPARS, or any other reasonable basis. [FAR 13.106-2, Evaluation of quotations or offers]

Responsibility is a separate check

The past performance comparison is separate from the responsibility determination. [FAR 15.305, Proposal evaluation] To be found responsible you must, among other things, have adequate financial resources or the ability to get them, be able to meet the schedule, and have a satisfactory performance record. You may not be found responsible or nonresponsible solely because you lack relevant performance history, except where a solicitation sets special standards. [FAR 9.104-1, General standards of responsibility] Special standards of responsibility must be set out in the solicitation itself, so read it closely. [FAR 9.104-2, Special standards of responsibility]

After your first award: CPARS

Agencies must prepare past performance evaluations for each contract that exceeds the simplified acquisition threshold, at least annually and when the work is completed, and enter them in CPARS. [FAR 42.1502, Past performance evaluation policy] Ratings run from Exceptional to Unsatisfactory, and you get up to 14 calendar days from notice to submit comments, rebuttals, or more information. [FAR 42.1503, Past performance evaluation procedures] Those evaluations may be used to support future award decisions, so your first job becomes the record for every bid after it. [FAR 42.1503, Past performance evaluation procedures]

Common questions

Will no past performance count against me?

Not on the past performance factor. The FAR says an offeror without a record of relevant past performance may not be evaluated favorably or unfavorably on past performance. [FAR 15.305, Proposal evaluation]

Can I use private or commercial jobs as past performance?

Yes. The solicitation must let offerors identify past or current contracts for similar work, including federal, state, local government, and private contracts. [FAR 15.305, Proposal evaluation]

Can my work as a subcontractor count?

Yes. Under SBA’s rule, agencies must consider the past performance of small businesses that were first-tier subcontractors, and a first-tier sub on a contract with a subcontracting plan can ask the prime for a rating. [13 CFR 125.11, Past performance ratings for certain small business concerns]

Can a contracting officer reject me just for being new?

Not on that basis alone. A prospective contractor may not be determined responsible or nonresponsible solely because it lacks relevant performance history, except under special standards stated in the solicitation. [FAR 9.104-1, General standards of responsibility] [FAR 9.104-2, Special standards of responsibility]

How long do I have to respond to a CPARS rating?

Up to 14 calendar days from the date you are notified the evaluation is available. [FAR 42.1503, Past performance evaluation procedures]

Sources

• FAR 15.305, Proposal evaluation
• FAR 9.104-1, General standards of responsibility
• FAR 15.304, Evaluation factors and significant subfactors
• 13 CFR 125.11, Past performance ratings for certain small business concerns
• FAR 14.101, Elements of sealed bidding
• FAR 13.106-2, Evaluation of quotations or offers
• FAR 9.104-2, Special standards of responsibility
• FAR 42.1502, Past performance evaluation policy
• FAR 42.1503, Past performance evaluation procedures

Checked against these sources on October 22, 2026. Rules change, so always read the current solicitation and regulation. This guide is general information, not legal advice.