Simplified Acquisition Procedures (FAR Part 13): A Guide for Software Companies

Most first federal sales for a software company are small. A team buys a few dozen seats, an office pilots a tool for a year, a program adds a module to an existing system. Most of those purchases sit under a single dollar line, the simplified acquisition threshold, and below it agencies use a lighter set of rules in FAR Part 13: shorter notices, quotations instead of formal proposals, and evaluations the contracting officer can shape to fit the buy.

This guide walks through how those rules work from the seller’s side: the thresholds, the small business reservation, how agencies solicit and evaluate quotes, when a single source is allowed, how a contract actually forms, and the commercial procedures that stretch simplified buying up to $9 million. It is written for founders and the first sales hire at a software company, and it builds on our guides to micro-purchases and small business set-asides.

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The thresholds

Two numbers in the FAR definitions at 2.101 set the ranges. Both took effect on 2025-10-01.

Range	What usually applies
Up to the micro-purchase threshold, $15,000	Purchases often made with the government purchase card, with no competition required when the price is reasonable. See our micro-purchases guide.
Above $15,000, up to the simplified acquisition threshold, $350,000	Simplified acquisition procedures under FAR Part 13, and a small business set-aside by default.
Above $350,000, up to $9 million, commercial only	Simplified procedures for commercial products and services under FAR subpart 13.5, with FAR part 12 terms.
Above that	Full procedures, usually a negotiated procurement under FAR Part 15.

The definition carries higher figures for purchases in support of contingency operations and certain emergencies, and subpart 13.5 rises to $15 million for the special cases in 13.500(c). For a typical civilian software buy, the four rows above are the ones that matter.

FAR 13.003(c)(2) adds a rule that protects the line: agencies may not break a requirement into several smaller purchases just to stay under a threshold or to avoid a requirement that applies above the micro-purchase threshold.

When simplified procedures do not apply

FAR 13.003(a) tells agencies to use simplified acquisition procedures to the maximum extent practicable for purchases at or below the threshold. The same paragraph lists three exceptions, where the agency can meet the need through:

• required sources under FAR part 8, which include Federal Supply Schedule contracts,
• an existing IDIQ contract, or
• other established contracts.

So a buyer who can order your product off a GSA Schedule, a BPA or an IDIQ vehicle the agency already uses may never run an open Part 13 buy at all. That is one reason a small software company with no vehicle sees a different slice of demand from a reseller that holds several.

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Small business by default

FAR 13.003(b)(1) is the sentence many small software companies never hear about: acquisitions with an anticipated value above the micro-purchase threshold, but at or below the simplified acquisition threshold, shall be set aside for small business concerns. It points to FAR 19.203 and subpart 19.5 for how the reservation works in practice.

Paragraph (b)(2) lets the contracting officer award to a small business under the 8(a), HUBZone, service-disabled veteran-owned and women-owned small business programs. Paragraph (b)(3) says a decision not to use one of those programs for a buy at or below the threshold is not subject to review under FAR subpart 19.4.

For a small software company, the practical point is that the $15,000 to $350,000 band is the part of the market most tilted toward you. Make sure your size representation in SAM.gov is current for the NAICS codes agencies use for software, and read our guides to size standards and affiliation and limitations on subcontracting, which can apply when a reseller or an integrator does part of the work.

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How the buy is announced

Notice rules depend on dollar value, and they come from FAR part 5.

• Above $25,000. FAR 5.101(a)(1) requires the contracting officer to synopsize the proposed action in the Governmentwide point of entry, which is SAM.gov.
• Above $20,000, up to $25,000. FAR 5.101(a)(2) requires a notice in a public place or by appropriate electronic means, posted no later than the solicitation date and kept up for at least 10 days or until quotes are opened, whichever is later.
• At $20,000 or below. FAR 5.101 sets no posting requirement, and the contracting officer may simply ask a few known sources for quotes.

FAR 5.203(a) generally requires the synopsis to appear 15 days before the solicitation is issued. For commercial products or commercial services, the contracting officer may set a shorter period or use the combined synopsis and solicitation at FAR 12.603, one notice that is both the announcement and the request for quotes. Many commercial software notices on SAM.gov in this range use that combined form.

Response windows are short. For actions above $25,000 and up to the simplified acquisition threshold, and for commercial buys above $25,000, FAR 5.203(b) requires only a response time that affords a reasonable opportunity to respond, set by the contracting officer with the complexity, commerciality, availability and urgency of the buy in mind. The 30-day minimum in 5.203(c) applies to non-commercial actions above the threshold. Expect some requests for quotes in this band to close within days. Our guides to finding federal contract opportunities and late proposals cover how to see them early and get quotes in on time.

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How agencies solicit quotes

FAR 13.104 sets the competition duty. The contracting officer must promote competition to the maximum extent practicable and must not:

• solicit quotations based on personal preference, or
• restrict solicitation to suppliers of well-known and widely distributed makes or brands.

When the agency is not posting the notice and solicitation through SAM.gov, 13.104(b) says to consider soliciting at least three sources, and, whenever practicable, to ask two sources that were not in the previous solicitation. A contracting officer who buys the same kind of software every year is told, in other words, to rotate in new names. Being on the list is a sales task. Our guides to federal buyer roles and sources sought notices and RFIs cover how companies get onto it.

FAR 13.106-1 adds the mechanics:

• Oral solicitation. At or below the threshold, the contracting officer shall solicit quotations orally to the maximum extent practicable when that is more efficient than electronic methods and no notice is required under 5.101. Paragraph (c)(2) cautions that oral solicitation may not be practicable above $25,000.
• Written basis of award. Paragraph (a)(2) requires the contracting officer to tell quoters the basis on which award will be made, price alone or price and other factors such as past performance and quality. Best value is encouraged. The solicitation does not have to state the relative importance of each factor or include subfactors.
• Options. Paragraph (e) allows options when the acquisition and all options together stay within the dollar limit for simplified procedures. A one-year subscription with four option years counts against the threshold at its full five-year value. Our guide to contract options covers how option years work.

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When one source is enough

FAR 13.106-1(b)(1) lets the contracting officer, for purchases at or below the threshold, solicit from one source when the circumstances leave only one source reasonably available. The examples in the rule are urgency, exclusive licensing agreements, brand name and industrial mobilization.

Exclusive licensing is the example software companies meet most. If your product is sold to the government only through you, or through one authorized reseller, that is the kind of fact this paragraph contemplates. The contracting officer still documents the reason. FAR 13.106-3(b)(3) requires a statement explaining the absence of competition when only one source is solicited. Where only part of a purchase names a brand, the documentation covers only that part. Our guides to brand name justifications, sole-source awards and federal resellers cover how that plays out.

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How quotes are evaluated

FAR 13.106-2 gives the contracting officer broad discretion to design the evaluation. The procedures in FAR parts 14 and 15 are not mandatory. The contracting officer may borrow some of them and leave the rest. The fixed points are that quotes are evaluated impartially, on the basis stated in the solicitation, and that every timely quote is considered.

When price and other factors are used, paragraph (b)(3) says the evaluation should be efficient and minimally burdensome. Formal evaluation plans, a competitive range, discussions and scoring are not required. Past performance can be judged from:

• the contracting officer’s own knowledge of and experience with the product,
• customer surveys and past performance questionnaires,
• the Contractor Performance Assessment Reporting System, CPARS, or
• any other reasonable basis.

That last line is why a software company with no federal history can still win here. A strong commercial reference, a short questionnaire answered by a customer, or a pilot the office already ran can carry real weight. Our guide to past performance covers how to build that record.

For electronic quotes, paragraph (b)(4) allows two shortcuts. The contracting officer can pick a suitable quote, such as the lowest-priced brand that meets the need, and quickly screen only the lower-priced quotes against readily visible value indicators like past performance, warranty and maintenance. Or, where the evaluation is price and past performance only, the contracting officer can ask whether the lowest-priced quote with the top past performance rating is the best value against any cheaper quote. Either way, a clear quote that states support terms, warranty and references up front is easier to pick.

Price reasonableness

FAR 13.106-3(a) requires the contracting officer to find the price fair and reasonable before award, ideally from competing quotes. When only one quote arrives, the file needs a statement of price reasonableness, which can rest on market research, prior purchases, a comparison with similar items, an independent government estimate or other reasonable grounds. The rule adds that a price in a price list, catalog or advertisement does not, by itself, establish that the price is fair and reasonable. A public price page helps, and a record of what comparable customers actually paid helps more. Our guide to price reasonableness goes further.

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A quote is not an offer

FAR 13.004 is short and worth knowing exactly:

• A quotation is not an offer. The government cannot accept it to form a binding contract.
• The order is the offer. When the government issues an order in response to your quote, the order is the government’s offer to buy on the terms it states.
• You accept. A contract is formed when you accept the order, by notifying the government (preferably in writing) or by delivering or performing to the point of substantial performance.
• Until then, it can change. Before acceptance, the government may withdraw, amend or cancel its offer by written notice.

Two practical consequences follow. First, read the purchase order, not just your quote. Terms the agency adds become part of the deal once you deliver, and starting work or provisioning accounts can count as acceptance. Second, if the order differs from what you quoted, raise it before you perform. Our guide to software license terms in federal contracts covers the commercial terms agencies can and cannot accept.

FAR 13.302-1 says purchase orders are generally fixed-price, state the quantity or scope and a delivery date, and provide for inspection and acceptance. Payment is by electronic funds transfer, so your banking details in SAM.gov need to be right before the first order. Our guides to SAM.gov registration and federal invoicing and prompt payment cover the setup.

Repeat purchases

For recurring needs, FAR 13.303-1 describes a blanket purchase agreement under Part 13 as a “charge account” with a qualified source: the terms are set once, and calls are placed against it as needs arise. Part 13 BPAs are separate from the BPAs agencies set up under GSA Schedules, which our BPA guide covers.

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Learning why you lost

Simplified buys do not come with the debriefing rights of a Part 15 procurement. FAR 13.106-3(c) says that, at or below the threshold and absent automatic electronic notice, unsuccessful suppliers are notified only if they ask or if FAR 5.301 requires it. Paragraph (d) says that if a supplier asks about an award based on factors other than price alone, the contracting officer shall give a brief explanation of the basis for the decision.

So ask. A short, polite request after an award on price and past performance often gets you the explanation the rule requires, and it tells you what to fix before the next buy. Our guide to debriefings covers what you get in larger competitions.

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Commercial buys up to $9 million

FAR subpart 13.5 stretches simplified procedures well above the threshold for commercial items. FAR 13.500(a) authorizes simplified procedures for acquisitions above $350,000 and up to $9 million, including options, when the contracting officer reasonably expects, from market research and the nature of the need, that offers will include only commercial products or commercial services. The ceiling is $15 million for the special cases in 13.500(c).

Most SaaS and commercial software fits that description. Paragraph (b) says FAR part 12 applies to these buys, including its provisions and clauses, so the commercial products rules govern the contract terms while Part 13 governs how the competition runs.

Single-source buys in this range need more paperwork than below the threshold. FAR 13.501(a) requires a written justification, approved at levels that rise with value:

Proposed contract	Approval
Above $350,000, up to $900,000	The contracting officer’s certification that the justification is accurate and complete
Above $900,000, up to $20 million	The advocate for competition for the procuring activity, or a higher official named in the rule
Above $20 million, up to $90 million ($150 million for the Department of War, NASA and the Coast Guard)	The head of the procuring activity, or a higher official named in the rule
Above that	The agency’s senior procurement executive

Justifications other than brand name ones are made public within 14 days after award. Brand name justifications are posted with the solicitation. The FAR text predates the department’s renaming and still uses its former name. The rules are the same.

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A checklist for software companies

• Know your band. Price your typical first deal and see which row of the threshold table it falls in, options included.
• Check your size status. Between $15,000 and $350,000, the buy is set aside for small business by default. Keep your SAM.gov size representations current.
• Watch for combined synopses. Search SAM.gov for combined synopsis and solicitation notices in your NAICS codes, and plan to answer within days.
• Get on the list. Below $25,000 there may be no public notice at all. Contracting officers ask sources they know, and are told to add new ones.
• Quote to the stated basis. If the request says price and past performance, put references, support terms and warranty in the quote itself.
• Bring pricing evidence. A price list alone does not prove reasonableness. Have recent comparable sales ready.
• Read the order before you perform. Your quote is not the contract. The order is, once you accept it.
• Ask why you lost. You will usually hear nothing unless you ask, and the contracting officer must give a brief explanation when factors other than price were used.
• Read the current rule text. The FAR is being rewritten under the Revolutionary FAR Overhaul, so section numbers and wording may move. This guide reflects the eCFR text read on 2026-11-04. Confirm the terms of each solicitation and get advice from counsel on specific situations.

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The short version

• The simplified acquisition threshold is $350,000, and the micro-purchase threshold is $15,000, both effective 2025-10-01.
• Purchases between the two are set aside for small business by default under FAR 13.003(b)(1).
• Notices are lighter. Above $25,000 the buy is synopsized on SAM.gov, and commercial buys can use one combined synopsis and solicitation with a short response window.
• Evaluation is flexible. No formal plan, competitive range, discussions or scoring is required, and past performance can come from any reasonable basis.
• A quotation is not an offer. The government’s order is the offer, and you accept it by notice or by performing.
• Commercial buys can use simplified procedures up to $9 million under FAR subpart 13.5, with FAR part 12 terms.

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Where this fits

Small buys are decided quickly, often by a contracting officer comparing a handful of quotes and whatever past performance evidence is easy to read. It helps to know how your company looks across the categories federal buyers review, verified and self-attested kept apart, before the request for quotes arrives. Score your company’s federal readiness to see where you stand.

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Related reading

• Micro-Purchases for Software Companies
• Small Business Set-Asides for Software Companies
• Commercial Products Under FAR Part 12
• Brand Name Justifications for Software Companies
• Price Reasonableness for Software Companies