How a contracting officer can sole-source to an SDVOSB under FAR 19.1406

Sole-source authority for service-disabled veteran-owned small businesses is one of the most direct tools a contracting officer has, and one of the least used. The rule is short. The file it requires is short. What slows it down is usually uncertainty about the conditions and a vendor who has not made the determination easy.

The rule in one paragraph

FAR 19.1406 allows a contracting officer to award a contract to a certified SDVOSB without competition when five conditions are met: the CO does not have a reasonable expectation that offers would be received from two or more SDVOSB concerns; the anticipated award price, including options, will not exceed $8.5 million for a manufacturing NAICS code or $5 million for any other NAICS code; the requirement is not currently being performed by an 8(a) participant or accepted by SBA under subpart 19.8; the SDVOSB has been determined responsible; and award can be made at a fair and reasonable price. Those figures are from FAC 2026-01, effective March 13, 2026; confirm the live text at acquisition.gov before you rely on it.

Note the order of operations. Set-aside comes first. The CO must first conclude that a set-aside under FAR 19.1405 is not appropriate, which in practice means the market research did not surface two or more capable SDVOSBs. That conclusion is what unlocks the sole-source path.

What the market research has to show

The determination turns on “reasonable expectation.” A CO does not have to prove that only one SDVOSB exists. The CO has to document the research that was done and why it did not produce a reasonable expectation of two SDVOSB offers. Typical evidence:

• A sources-sought or request-for-information notice on SAM.gov and the responses, or the absence of responses.
• A search of the SBA certification database for the NAICS code and the relevant capabilities.
• Contact with the agency’s small-business specialist and OSDBU.
• Prior competitions for similar requirements and who offered.

For custom software and digital modernization work in NAICS 541511, a specific capability description matters. “IT services” returns hundreds of firms. “Section 508-conformant public portal with intake, routing, and reporting for a program office of 40 users” returns a much shorter list, and the research reflects the actual requirement.

What the SDVOSB should hand you

A firm that wants a sole-source award should make the file easy to build. At minimum:

1. Certification evidence. The SBA VetCert record, with the certification date and expiration, that matches the SAM registration exactly. Under FAR 19.1403, status is established through SBA certification; a self-representation is not enough.
2. A capability statement that maps to the requirement. Not a brochure. A one-page statement of what the firm will do, the deliverables, and the acceptance evidence, in the terms the program office uses.
3. A price basis. Enough labor category, hours, and rate detail for the CO to make the fair-and-reasonable determination without a second round.
4. A responsibility package. Active SAM registration, no exclusions, financial capacity for the period of performance, and the relevant experience of the people who will perform, whether or not the firm has prior federal awards.

Be Chosen Agency publishes all four on its capability statement page so a CO can start the file from the public record.

The 8(a) check

Before sole-sourcing, confirm the requirement is not currently performed by an 8(a) participant and has not been accepted into the 8(a) program. If it has, the requirement generally stays in 8(a) unless SBA releases it. This is a quick check with the agency’s 8(a) liaison, and it belongs in the file.

Documentation the file needs

• The market research summary and the conclusion that a set-aside is not appropriate.
• The SDVOSB’s SBA certification record and SAM registration.
• The 8(a) status check.
• The responsibility determination.
• The fair-and-reasonable price determination.
• The sole-source justification citing FAR 19.1406, if your agency requires a separate memorandum.

Where sole-source fits with the other paths

Under the simplified acquisition threshold, FAR Part 13 often gives a CO a faster route, and micro-purchases need no competitive quotations at all when the price is reasonable. Above the SDVOSB sole-source ceiling, the requirement belongs in a set-aside or a competition. Sole-source under FAR 19.1406 is the middle path: a bounded requirement, a certified firm, a fair price, and a short file.

How Be Chosen Agency approaches a sole-source conversation

BCA proposes bounded work packages with explicit deliverables and acceptance evidence, priced with labor detail, and it states plainly what it does not yet have, including federal past performance. That candor is deliberate. A sole-source file is easier to defend when the vendor’s claims match the record. Send the requirement to Teton Wilson and expect a written scope within two business days.