DFARS Part 219 Rewrite Changes SDVOSB Verification and Moves Subcontracting Reports to SAM.gov

What changed

On 24 July 2026 the Principal Director, Defense Pricing, Contracting, and Acquisition Policy issued Class Deviation 2026-O0037, Revision 1, revising DFARS Part 219, Small Business, DFARS Appendix I (the Mentor-Protege Program), and PGI 219. It revises and supersedes Class Deviation 2026-O0037 of 21 January 2026, and it also supersedes Class Deviation 2024-O0002, Revision 1, The Service-Disabled Veteran-Owned Small Business Program, issued 14 March 2024. Four items are concrete.

First, SDVOSB status verification. New DFARS 219.106-70(a) directs the contracting officer, in lieu of the procedures at FAR 19.106-1(b), to verify that an offeror seeking an SDVOSB set-aside or sole-source award is designated as an SDVOSB concern certified by SBA in the Small Business Search at search.certifications.sba.gov.

Second, joint ventures. DFARS 219.106-70(b), in lieu of FAR 19.106-1(c)(2), provides that a joint venture may be considered an SDVOSB concern eligible under the program if the managing SDVOSB joint venture partner is designated in the Small Business Search as an SBA-certified SDVOSB. The deviation states these alternate procedures are necessary until SAM.gov aligns with FAR procedures.

Third, subcontracting reporting. The deviation reflects the decommissioning of the Electronic Subcontracting Reporting System on 20 February 2026 and the move to the new Subcontracting Plan Reporting system in SAM.gov. The deviation clause at 252.219-7996, Small Business Subcontracting Plan (DoD Contracts), together with its Alternates I and II, and the deviation clause at 252.219-7997, Small Business Subcontracting Plan (Test Program), are revised to reflect the new system, along with PGI 219.302-2 and 253.219-70.

Fourth, an 8(a) threshold correction. DFARS 219.208-2 is corrected from $150 million to $100 million. In lieu of the threshold at FAR 19.208-2(a), SBA may not accept for negotiation a defense sole-source 8(a) contract that exceeds $100 million unless a justification has been completed in accordance with FAR 6.104 and DFARS 206.104-70.

What a contractor does differently

The operative record for SDVOSB eligibility on a defense set-aside or sole-source award is now the firm's entry in SBA's Small Business Search, not a SAM.gov representation. A firm whose SBA certification is in process, lapsed, or reflected inconsistently between the two systems should expect the contracting officer to look at the SBA record. For a joint venture, it is the managing partner's certification that is checked, so the JV agreement and the managing partner designation need to match what SBA shows.

Prime contractors with subcontracting plans should confirm their reporting is running through SAM.gov rather than eSRS, and that the clause version in a given contract matches the deviation clauses rather than the codified 252.219-7003 and -7004. On the 8(a) side, the sole-source justification trigger sits at $100 million, not the $150 million figure carried in the January version of the deviation.

Primary sources

Class Deviation 2026-O0037, Revision 1 (24 July 2026): https://www.acq.osd.mil/dpap/dars/classdev/DFARS_RFO/Part-219/2026-O0037_Rev1_TAB_A_Class_Deviation_Part_219.pdf

Revolutionary FAR Overhaul, FAR Part 19: https://www.acquisition.gov/far-overhaul/far-part-deviation-guide/far-overhaul-part-19

SBA Small Business Search: https://search.certifications.sba.gov/