Every federal contractor was once a company with no federal past performance. The question is how to compete while you build that record. The FAR gives you more room than many new contractors realize, and there are practical ways to show an evaluator that you can do the work. For general advice on writing references, see how to write past performance.
What the FAR actually says
FAR 15.305(a)(2) sets several rules that help new entrants in negotiated procurements:
- Non-federal work counts. The solicitation must give offerors an opportunity to identify past or current contracts — including federal, state and local government and private — for efforts similar to the requirement (15.305(a)(2)(ii)).
- Related experience can be considered. The evaluation should take into account past performance of predecessor companies, key personnel who have relevant experience, or subcontractors that will perform major or critical aspects of the requirement, when relevant (15.305(a)(2)(iii)).
- No record is neutral. An offeror without a record of relevant past performance, or for whom information is not available, may not be evaluated favorably or unfavorably on past performance (15.305(a)(2)(iv)).
- Joint ventures. For joint venture offerors, if the joint venture itself does not demonstrate past performance, the contracting officer shall consider the past performance of each party to the joint venture (15.305(a)(2)(vi)).
The solicitation must also describe how it will evaluate offerors with no relevant performance history. Read that part of Section M (or the evaluation criteria) carefully.
Neutral is not the same as winning
A neutral rating means you are not penalized for having no record — but a competitor with strong, relevant past performance may still rate higher in a best-value tradeoff. Your goal is to give evaluators as much relevant, verifiable evidence as the solicitation allows, and to choose opportunities where past performance carries less weight.
Ways to show relevant experience
Commercial and state or local work
This is the most direct substitute. Choose projects that resemble the federal requirement in scope, size and complexity, and explain the similarities explicitly. A hospital cleaning contract may be very relevant to a VA medical center requirement; a school district IT help desk may be relevant to an agency service desk.
Key personnel experience
If your managers or technical leads did similar work at previous employers, the evaluation may consider it when relevant. Present it clearly as the individual's experience — role, employer, dates and scope — not as company past performance. Follow the solicitation's instructions on where this belongs.
Predecessor companies
If your business grew out of a predecessor — for example, through a reorganization — its relevant record may be considered. Explain the relationship clearly.
Subcontractors and teaming partners
A subcontractor that will perform a major or critical part of the work can contribute relevant past performance. Be careful on set-asides: the limitations on subcontracting and SBA's affiliation rules still apply. See teaming agreements vs joint ventures.
Joint ventures and mentor-protégé
A joint venture can draw on the past performance of each party. SBA's Mentor-Protégé Program allows a protégé to joint venture with an experienced mentor and compete for small business set-asides if the protégé qualifies. See SBA Mentor-Protégé Program.
Choose opportunities that fit
- Simplified acquisitions, where evaluation is lighter and price often dominates. See simplified acquisition procedures.
- Micro-purchases, which build relationships and a track record. See micro-purchases.
- Lowest price technically acceptable procurements, where past performance may be pass/fail or a smaller factor.
- Subcontracts under experienced primes. See subcontracting to prime contractors.
Build the record deliberately
- On every job, keep a short project record: customer, contact, scope, dates, value, outcomes, and any problems you solved.
- Ask satisfied customers in advance whether they will serve as references and complete questionnaires.
- Once you have federal work, you will be evaluated in CPARS. Treat every evaluation as a future proposal asset, and respond factually to any you disagree with.
What not to do
- Do not present an employee's former employer's contract as your company's past performance.
- Do not claim a partner's experience without their agreement and without making the relationship clear.
- Do not exaggerate scope, value or outcomes. Evaluators can and do check references and government records.
Presenting non-federal work so evaluators can use it
Write each commercial or state and local reference in the same structure you would use for a federal contract: customer, contract or purchase order number if any, period of performance, value, your role, a scope summary and a point of contact. Then add an explicit relevance statement that maps the work to the new requirement's tasks, size and complexity. Evaluators can only credit what they can find and verify.
Frequently asked questions
Can I win a federal contract with no past performance at all?
Yes. Under FAR 15.305(a)(2)(iv), offerors without a relevant record may not be evaluated favorably or unfavorably on past performance, and many simplified acquisitions weigh price heavily. Your odds improve when you can show relevant commercial or personnel experience.
Does commercial work count as past performance?
Generally yes. FAR 15.305(a)(2)(ii) requires solicitations to let offerors identify similar federal, state, local and private contracts.
Can I use my employees' prior experience?
The evaluation should take relevant key personnel experience into account where relevant. Present it as the individuals' experience and follow the solicitation's instructions.
What does a neutral past performance rating mean?
That you were not rated favorably or unfavorably because you had no relevant record. It avoids a penalty but may not beat a competitor with a strong record.
This guide is general information, not legal advice. Rules change — always check the solicitation and the official sources linked here.