FAR 19.305—Reviews of SDB status.
Plain-English Summary
FAR 19.305 explains how the government reviews a firm’s small disadvantaged business (SDB) status when that firm has represented itself as an SDB on a prime contract or subcontract. It covers when the Small Business Administration (SBA) may start a review, what kind of information can trigger that review, where requests for review may be sent within SBA, and how an SDB status review differs from a formal protest. The section also points readers to the separate protest procedures that apply to a concern’s size as a prime contractor and as a subcontractor, making clear that SDB status review is not the same as a size protest. In practice, this section matters because an SDB representation can affect eligibility for set-asides, evaluation preferences, subcontracting opportunities, and compliance risk. Contracting officers, prime contractors, and subcontractors should understand that credible information can prompt SBA scrutiny and that the correct procedural path depends on whether the issue involves SDB status or size status, and whether the firm is acting as a prime or subcontractor.
Key Rules
SBA may initiate review
SBA can begin a review of a firm’s SDB status whenever it receives credible information that calls the firm’s SDB representation into question. This applies to firms that have represented themselves as SDBs on either prime contracts or subcontracts tied to Federal prime contracts.
Applies to prime and subcontractors
The section covers SDB status reviews for both prime contractors and subcontractors. The rule is not limited to one contracting tier, so a challenged representation at either level can be reviewed by SBA.
Requests may be forwarded to SBA
Requests for an SBA review of SDB status may be sent to the SBA Associate Administrator for Business Development (AA/BD) at the address listed in the regulation. This provides a formal channel for raising concerns about a firm’s SDB representation.
Not the same as a protest
An SBA review of a subcontractor’s SDB status is different from a formal protest. The regulation distinguishes SDB status review from size protests and directs readers to the separate protest procedures that apply to prime and subcontractor size determinations.
Separate size protest procedures apply
Protests of a concern’s size as a prime contractor are handled under FAR 19.302, while protests of a concern’s size as a subcontractor are handled under FAR 19.703(b). This means parties must use the correct process depending on whether the issue is SDB status or size.
Responsibilities
SBA
May initiate a review of a firm’s SDB status when it receives credible information questioning the firm’s representation. SBA also receives forwarded requests for review through the AA/BD office.
Contracting Officers
Should recognize when concerns involve SDB status versus size and route issues through the proper SBA or protest procedures. They should not treat an SDB status review as the same thing as a size protest.
Prime Contractors
Must ensure any SDB representation made for themselves or their subcontractors is accurate and supportable. If credible information raises a question about a subcontractor’s SDB status, they should expect possible SBA review and use the correct reporting or protest channels as appropriate.
Subcontractors
Must accurately represent their SDB status when they claim it on a subcontract tied to a Federal prime contract. If their status is questioned, they may be subject to SBA review under this section.
Concerned Parties/Protestors
May forward requests for SBA review of SDB status to the AA/BD when they have credible information. They must also use the separate FAR protest procedures when the issue is size rather than SDB status.
Practical Implications
A firm’s SDB representation can be reviewed based on credible information, so contractors should maintain documentation supporting status claims.
Do not confuse SDB status review with a size protest; using the wrong process can delay resolution or send the issue to the wrong office.
This section applies to both prime and subcontractor representations, so subcontract-level claims are not insulated from SBA scrutiny.
Contracting personnel should route issues carefully: SDB status concerns go to SBA review, while size disputes follow FAR 19.302 or 19.703(b) depending on contract tier.
Because the regulation is procedural, the main risk is misclassification of the issue; parties should identify whether the concern is about SDB status, size, or both before acting.
Official Regulatory Text
This section applies to reviews of a small business concern's SDB status as a prime contractor or subcontractor. (a) SBA may initiate the review of SDB status on any firm that has represented itself to be an SDB on a prime contract or subcontract to a Federal prime contract whenever it receives credible information calling into question the SDB status of the firm. (b) Requests for an SBA review of SDB status may be forwarded to the Small Business Administration, Associate Administrator for Business Development (AA/BD), 409 Third Street, SW, Washington, DC 20416. (c) An SBA review of a subcontractor's SDB status differs from a formal protest. Protests of a concern's size as a prime contractor are processed under 19.302 . Protests of a concern's size as a subcontractor are processed under 19.703 (b).