FAR 13.303-5—Purchases under BPAs.
Plain-English Summary
FAR 13.303-5 explains how purchases may be made under blanket purchase agreements (BPAs) and sets the guardrails for using them properly. It covers what kinds of purchases may be placed against a BPA, dollar limits on individual purchases, special exceptions for certain BPA types and commercial-item procedures, the rule that BPAs do not eliminate competition or small business considerations, what to do when there are too few BPAs to ensure maximum practicable competition, and how much documentation is required for BPA purchases. In practice, this section is about speed and simplicity without losing legal compliance: a BPA can streamline recurring buys, but each order still has to be authorized, within the applicable dollar limits, competitively placed when required, and documented enough to support the transaction. It also reinforces that BPA use does not excuse agencies from small business set-aside requirements or from seeking additional sources when competition is inadequate. Finally, it gives practical recordkeeping guidance for electronic, oral, and paper purchases, including how receipt and acceptance may be documented.
Key Rules
Use only authorized purchases
A BPA may be used only for purchases that are otherwise authorized by law or regulation. The BPA is a buying method, not independent authority to buy something the agency could not otherwise purchase.
Observe purchase dollar limits
Individual purchases under a BPA generally may not exceed the simplified acquisition threshold. Agency regulations may allow a higher threshold only where consistent with the specific exceptions stated in the rule, including the special limits for certain BPAs and commercial-item acquisitions.
Special BPA exceptions apply
The simplified acquisition threshold and the $9 million individual-purchase limitation do not apply to BPAs established under 13.303-2(c)(3). For commercial products and commercial services acquisitions under subpart 13.5, the individual-purchase limit is $9 million, or $15 million for acquisitions described in 13.500(c).
BPA use does not replace competition
The existence of a BPA does not justify buying from only one source or bypassing small business set-asides. The requirements of 13.003(b) and subpart 19.5 apply to each order, so the contracting officer must still consider competition and small business programs for every purchase.
Seek more sources when competition is thin
If there are not enough BPAs for a purchase over the micro-purchase threshold to ensure maximum practicable competition, the contracting officer must solicit quotations from other sources and make the purchase appropriately. If recurring needs are likely and qualified sources are willing, additional BPAs should be established when practical.
Keep documentation to essentials
Purchases should generally be made electronically, or orally when electronic methods are not economical or practical. Essential elements such as date, supplier, item or service, price, and delivery date must be recorded unless a paper purchase document is issued, and the requisition and accounting/appropriation data must be cited.
Document receipt and acceptance
When delivery or performance occurs, the supplier’s sales document, delivery document, or invoice may serve as the receipt-and-acceptance record if it contains the essential elements. If another activity administers the purchase, the authorized Government representative must sign and date the agency-specified form after verifying the supplies or services and noting any exceptions.
Responsibilities
Contracting Officer
Ensure each BPA purchase is legally authorized, stays within the applicable dollar limits, and is placed in a way that preserves competition and complies with small business requirements. When there are too few BPAs to ensure maximum practicable competition, solicit quotations from other sources and establish additional BPAs when recurring needs, willing sources, and practicality support doing so.
Agency
May issue regulations that establish a higher individual-purchase threshold for BPA orders only to the extent allowed by this section and the referenced exceptions. Agencies must also support proper documentation and administration procedures for BPA purchases.
Purchasing Activity / Buyer
Place orders under BPAs using the required method, generally electronically or orally when appropriate, and record the essential transaction details and funding data. Ensure the purchase record is complete enough to support the order and later audit or review.
Authorized Government Representative
When another activity administers the purchase, verify receipt and acceptance of the supplies or services, sign and date the agency-specified form, and note any exceptions to the delivery or performance.
Supplier / BPA Holder
Provide the ordered supplies or services in accordance with the BPA order and furnish sales, delivery, or invoice documents that reflect the essential transaction elements when those documents are used to record receipt and acceptance.
Small Business Program Officials / Contracting Team
Ensure BPA orders are evaluated for small business set-aside applicability and that BPA usage does not bypass subpart 19.5 requirements or other small business policies.
Practical Implications
A BPA can speed up recurring buys, but it does not create blanket authority to purchase anything or to ignore competition rules. Each order still needs its own legal basis and must fit the applicable dollar ceiling.
A common mistake is treating a BPA as a sole-source arrangement by default. This section specifically warns against that and requires attention to maximum practicable competition and small business set-asides for each order.
Contracting staff should watch the dollar thresholds carefully, especially the special exceptions for certain BPAs and commercial-item procedures. Misapplying the simplified acquisition threshold or the $9 million/$15 million limits can make an order noncompliant.
Documentation can be light, but it cannot be absent. Even when purchases are made electronically or orally, the essential facts and funding data must still be recorded, and receipt/acceptance must be supportable.
If the existing BPAs do not provide enough competition for a purchase above the micro-purchase threshold, the contracting officer should not simply proceed with the limited pool. The rule expects outreach to other sources and, where practical, creation of additional BPAs for future needs.
Official Regulatory Text
(a) Use a BPA only for purchases that are otherwise authorized by law or regulation. (b) Individual purchases shall not exceed the simplified acquisition threshold. However, agency regulations may establish a higher threshold consistent with the following: (1) The simplified acquisition threshold and the $9 million limitation for individual purchases ($15 million for purchases entered into under the authority of 12.102 (f)(1)) do not apply to BPAs established in accordance with 13.303-2 (c)(3). (2) The limitation for individual purchases for commercial products and commercial services acquisitions conducted under subpart 13.5 is $9 million ($15 million for acquisitions as described in 13.500 (c)). (c) The existence of a BPA does not justify purchasing from only one source or avoiding small business set-asides. The requirements of 13.003 (b) and subpart 19.5 also apply to each order. (d) If, for a particular purchase greater than the micro-purchase threshold, there is an insufficient number of BPAs to ensure maximum practicable competition, the contracting officer shall- (1) Solicit quotations from other sources (see 13.105 ) and make the purchase as appropriate; and (2) Establish additional BPAs to facilitate future purchases if- (i) Recurring requirements for the same or similar supplies or services seem likely; (ii) Qualified sources are willing to accept BPAs; and (iii) It is otherwise practical to do so. (e) Limit documentation of purchases to essential information and forms as follows: (1) Purchases generally should be made electronically, or orally when it is not considered economical or practical to use electronic methods. (2) A paper purchase document may be issued if necessary to ensure that the supplier and the purchaser agree concerning the transaction. (3) Unless a paper document is issued, record essential elements ( e.g., date, supplier, supplies or services, price, delivery date) on the purchase requisition, in an informal memorandum, or on a form developed locally for the purpose. (4) Cite the pertinent purchase requisitions and the accounting and appropriation data. (5) When delivery is made or the services are performed, the supplier’s sales document, delivery document, or invoice may (if it reflects the essential elements) be used for the purpose of recording receipt and acceptance of the supplies or services. However, if the purchase is assigned to another activity for administration, the authorized Government representative shall document receipt and acceptance of supplies or services by signing and dating the agency specified form after verification and after notation of any exceptions.