The one sentence that governs the whole question
A new firm reads the past performance section of an RFP and sees a wall: three references, contracts of similar size and scope, CPARS ratings within the last three years, questionnaires due to the contracting officer a week before proposals. The firm has none of it. The usual reactions are to skip the bid or to write something vague and hope nobody checks. Both are avoidable, because the rule anticipated the situation. FAR 15.305(a)(2)(iv) says: "In the case of an offeror without a record of relevant past performance or for whom information on past performance is not available, the offeror may not be evaluated favorably or unfavorably on past performance."
That is a prohibition on the evaluator, not a courtesy to the offeror. An agency may not assign a low confidence rating because the file is empty. It also may not assign a high one. The result is a neutral rating, and neutral is a defined, defensible place to stand. GAO has been consistent on the point for decades: an empty record is not a deficiency, and treating it as one is grounds for a protest.
What the sentence does not do matters just as much. It does not waive the past performance factor. It does not reach any other evaluation factor. And it does not apply when a firm has a record that is simply bad, or when it has relevant work it failed to submit. The rule protects the firm with nothing, not the firm that chose to say nothing.
Neutral is a floor, not a score
In a best-value tradeoff under FAR 15.101-1, the source selection authority weighs what a technical advantage is worth against price. Neutral means the evaluator cannot count the empty file against you. It also gives you nothing to trade with. A competitor holding Exceptional ratings on three closely relevant contracts owns a discriminator you cannot match at any price.
The practical consequence is a bid selection rule more than a writing rule. Read Section M before Section L. Where past performance carries weight equal to technical, a firm with no record is playing on a board with a third of the surface unavailable. Where technical approach is significantly more important, or where past performance is evaluated only as acceptable or unacceptable, the empty file costs little. Those are the competitions worth the proposal hours.
How far each substitute travels with an evaluator
Editorial weighting from the FAR text and public source-selection practice. Illustrative, not a measured statistic.
The trap: experience and past performance are different factors
This is the mistake that costs new firms awards they thought were protected. FAR 15.305(a)(2)(iv) covers the past performance factor. It says nothing about a technical subfactor named "corporate experience" or "relevant experience," and many solicitations carry exactly that, worded to ask how many similar efforts the offeror itself has completed.
There is no neutral rule there. A firm with no corporate experience can be, and routinely is, rated lower on an experience subfactor without any violation of the FAR. The two words are interchangeable in ordinary English and not in a source selection. Past performance asks how well you did the work. Experience asks whether you have done it at all.
The response is to read the criteria word by word and find where the experience question actually lives. If it sits under technical, answer it with the experience of the individuals and teammates you are bringing, which is legitimate unless the solicitation forbids it, and say plainly which experience belongs to whom.
"No relevant past performance" protection does not extend to an experience subfactor
If the criteria say past performance, the neutral rule applies. If they say corporate experience, relevant experience, or demonstrated capability under the technical factor, it does not, and an empty column is a real weakness. Determine which one you are answering before you write a word.
What the solicitation owes you
FAR 15.305(a)(2)(ii) puts two obligations on the government: "The solicitation shall describe the approach for evaluating past performance, including evaluating offerors with no relevant performance history, and shall provide offerors an opportunity to identify past or current contracts (including Federal, State, and local government and private) for efforts similar to the Government requirement."
Both halves are useful. If an RFP is silent on how offerors with no relevant history will be handled, that is a fair question during the Q&A window, and asking it is routine. The answer often reveals whether the buying office is open to a newcomer at all.
The parenthetical in that sentence is the part most first-time bidders leave on the table. State and local government contracts are citable. University subawards are citable. Private, commercial work is citable, by rule and by name. And the word "current" is doing real work: work in progress counts. A contract signed four months ago with three months of performance behind it is a citable reference, and the rule says so in plain words.
Making a commercial reference land
Citable is not the same as persuasive. FAR 15.305(a)(2)(ii) leaves relevance to the source selection authority, so the burden of drawing the line sits with the offeror. Write the relevance argument out. Do not leave it implied and hope the evaluator does the work.
A relevance argument names the dimensions and the deltas: "This engagement was $180,000 against a $600,000 requirement here. The technical work was the same work, structured extraction from a two-million-page corpus with a human review queue and an audited error rate. Period of performance was eleven months against twelve, and processed volume was within a factor of two." An evaluator can act on that. "Similar in scope and complexity" gets skimmed.
A private reference has one structural handicap: no CPARS entry exists for the contracting officer to pull, so verification depends on a human answering a phone. Supply name, title, direct phone, email, contract or purchase order number, dollar value and dates, then tell that customer a questionnaire may arrive with a short deadline. A reference surprised by the call is worth less than one who was warned.
Key personnel and predecessor companies
FAR 15.305(a)(2)(iii) opens the third door: "The evaluation should take into account past performance information regarding predecessor companies, key personnel who have relevant experience, or subcontractors that will perform major or critical aspects of the requirement when such information is relevant to the instant acquisition."
For a technical firm built around a founder or a small senior team, key personnel is the strongest substitute available. Four things make it work: name the individual, name the effort, state what that person personally did, and commit them at a labor share that matches the claim. An evaluator who reads a decade of relevant work in a resume and then finds that person at five percent time in the staffing plan discounts the argument, correctly.
The limit is attribution. An individual's record belongs to the individual. Write "the principal investigator led the data engineering for that program while at his prior employer," never "our firm delivered that program." The first is verifiable and credited. The second is a misrepresentation that one reference call destroys, and it puts the firm's honesty in play on every other page.
Predecessor-company experience is narrower than most firms assume. It applies where corporate lineage is real: a novated contract under FAR Subpart 42.12, a name change, a reorganization or asset purchase that carried the performing entity forward. A founder's former employer is not a predecessor company, and calling it one is a false statement on a federal proposal.
The subcontractor's record, and which way it travels
A prime may cite the record of a subcontractor who will perform major or critical aspects of the requirement. The direction is fixed: the prime can point at the sub's record, and the sub cannot point at the prime's. When a new firm joins an experienced team as a subcontractor, the past performance narrative belongs to the prime, and the newcomer contributes technical content and named people rather than borrowed credibility.
Three conditions decide whether a cited subcontractor record is credited. The sub must hold a defined, material work share. The cited work must map to the scope that sub actually owns here. And the solicitation must allow it, since some instructions cap references or require that at least one belong to the offeror itself. A ten percent subcontractor with excellent ratings on unrelated work moves nothing.
| Substitute | What the rule permits | Where it stops |
|---|---|---|
| No record at all | Neutral rating on past performance, FAR 15.305(a)(2)(iv) | Does not reach a corporate-experience subfactor under the technical factor |
| Key personnel | Individual records considered when relevant, FAR 15.305(a)(2)(iii) | Credited to the person, not the firm; discounted if the labor share is thin |
| Predecessor company | Considered where corporate lineage is real (novation, name change, reorganization) | A founder's former employer is not a predecessor company |
| Subcontractor record | Prime may cite a sub performing major or critical aspects | Never travels upward: a sub cannot claim the prime's record |
| Current and private work | Federal, state, local and private contracts, past or current, FAR 15.305(a)(2)(ii) | No CPARS entry to verify; relevance must be argued, not asserted |
| Letters of support | Evidence of interest, transition intent, commercial potential | Not past performance; a stack of them fills no evaluation factor |
Getting a rating for work you already did as a sub
Section 868 of the FY2021 NDAA created a route many small firms still do not use. SBA implemented it at 13 CFR 125.11, effective August 22, 2022: a small business that performed as a first-tier subcontractor may request a performance rating from the prime, then use that rating on its own prime-contract offers.
The mechanics are specific. The request goes to the prime within 30 days after the period of performance on the prime's government contract ends. The prime provides the rating within 15 calendar days. The rating uses the FAR 42.1503 five-level scale: exceptional, very good, satisfactory, marginal, unsatisfactory. The same regulation lets a small business use the record of a joint venture it belonged to, provided it identifies the work it personally performed, and SBA added a matching obligation to small business subcontracting plan requirements.
The 30-day clock is where this falls apart. By the time a small firm thinks about references, the subcontract closed eight months ago and the window is gone. Put the request date on a calendar the week the subcontract is signed, and name the person at the prime who will sign it.
Letters of support, and what they are not
A letter of support is an assertion of interest, evaluators read it as exactly that, and a thick appendix of them fills no evaluation factor. Their honest use is in commercialization and transition sections, where the question is whether anyone wants the outcome rather than whether you have delivered before.
What separates a letter worth reading from filler: it is signed by someone with budget or program authority rather than a friendly engineer, it commits to something specific such as furnishing test data or running an evaluation on the writer's own system, and it is written in the writer's voice. Evaluators recognize a letter you drafted and circulated for signature. The tell is that three letters from three organizations share a sentence structure.
Check the instructions before spending the relationship. Some solicitations exclude letters from the page count, some count them against it, and some prohibit them and treat inclusion as a compliance problem.
Responsibility is a separate gate
Passing the evaluation is not the last hurdle. Before award, the contracting officer makes a responsibility determination under FAR 9.104-1: adequate financial resources, ability to meet the schedule, a satisfactory performance record, a satisfactory record of integrity and business ethics, and the necessary organization, experience, accounting and operational controls, and technical skills. A new firm can trip here for reasons unrelated to the technical evaluation.
Small businesses have a specific protection. Under FAR 19.602-1, when a contracting officer finds that an apparent successful small business offeror lacks certain elements of responsibility, the CO must withhold award and refer the matter to the cognizant SBA Area Office. That is the entry to the Certificate of Competency process, and a COC issued by SBA is binding on the agency. It takes time and it is not automatic, but it exists because a nonresponsibility finding would otherwise end a small firm's first competition.
The preparation is unglamorous: an accounting system that survives a review, a documented cash position or line of credit sized to the contract, and a teaming structure that visibly covers any capability the firm does not hold in-house.
SBIR and grants run a different scoring sheet
This is why research programs are the standard entry lane for a technical firm with no federal record. The SBIR Policy Directive sets three Phase I evaluation criteria: technical merit and innovation, the qualifications of the principal investigator and supporting staff and consultants, and the potential for commercial application. A corporate performance record is not among them. The scoring runs on the quality of the idea and the credibility of the people, which is a board a two-person firm can win.
What the award builds depends on the instrument. A Phase I awarded as a contract above the simplified acquisition threshold triggers a CPARS evaluation under FAR 42.1502. That threshold rose from $250,000 to $350,000 effective October 1, 2025, so a meaningful share of Phase I contracts now sit below it and generate no CPARS entry. Grant programs at NIH, NSF and DOE never produce one. Either way the award still yields something citable: a federal contract or grant number, a technical point of contact who watched the work, and a final report.
Building a citable record on purpose
The first eighteen months should run three tracks at once, because each produces a different artifact and no single track produces all of them.
First 18 months: what to run in parallel
One detail worth planning around: FAR 42.1503 directs agencies to use CPARS information within three years of completion of performance for most contract types. A record built now is a working asset for three years and then ages out of the standard lookback. That argues for a steady cadence of small completed efforts rather than one large one, at least until a Phase II or a production contract carries the firm.
What to write in the volume itself
Four moves, in this order. State plainly that the firm holds no CPARS-rated federal prime contracts, and cite FAR 15.305(a)(2)(iv) in one sentence so the evaluator knows you understand the standard being applied. Present each substitute labeled honestly for what it is: a key-personnel record, a subcontract, a commercial engagement. Write a relevance argument for each, with numbers in it. Close with a contact block a contracting officer can actually call.
Do not pad. Four pages of adjacent work dressed up as federal delivery reads as evasion and invites the evaluator to check. A short, correctly cited volume protects the credibility of every technical claim elsewhere in the proposal. An empty record is neutral by rule. An overstated record is unfavorable by fact, and it can follow the firm into the responsibility determination.
Bottom line
The FAR gives a first-time bidder a defined place to stand and three named doors: the people, the teammates, and the work already done outside the federal market. The firms that lose on past performance are rarely the firms with no record. They are the firms that answered an experience subfactor with a neutral-rating argument, let a real commercial reference sit in an appendix without a word of relevance around it, or missed a 30-day window to convert a finished subcontract into a rated one. All three are avoidable with a careful read of the criteria and a calendar.
Frequently asked questions
It means the evaluator may not score the offeror favorably or unfavorably on that factor because no relevant record exists, per FAR 15.305(a)(2)(iv). The offeror is neither credited nor penalized, and the competition is decided on the remaining factors.
Yes. FAR 15.305(a)(2)(ii) requires solicitations to give offerors an opportunity to identify past or current contracts including federal, state, local government and private. Relevance is determined by the source selection authority, so the offeror should argue relevance explicitly with dollar value, scope and complexity comparisons.
Under 13 CFR 125.11, a first-tier small business subcontractor may request a rating from the prime within 30 days after the prime contract's period of performance ends. The prime must provide it within 15 calendar days using the FAR 42.1503 five-level scale.
No. A letter states interest or intent, not performance. Letters carry weight in commercialization and transition sections when they are signed by someone with authority and commit to something specific, but they do not fill a past performance factor.
For a small business, FAR 19.602-1 requires the contracting officer to withhold award and refer the matter to the SBA Area Office, which may issue a Certificate of Competency. A COC is binding on the agency, and the process exists so that a thin corporate history does not automatically end a first competition.