Contracting officers do not browse SAM the way you browse it. They run the same few searches, the same way, under deadline, with a market research memo to write at the end. If your profile is not built for those searches, you are not in the results. And if you are not in the results, nothing else about your firm matters.
The memo is the part firms never picture. FAR 10.002(e) makes the head of the agency document the research in a manner suited to the buy’s size and complexity, and FAR 4.803(a)(6) files it in the contract file with the set-aside decision. Nobody is shopping. They are assembling evidence, on a deadline, that has to survive somebody else’s read.
Why the search happens at all
FAR 10.001(a)(2) requires research before an agency writes a new requirements document, before it solicits offers above the simplified acquisition threshold, and before anything that could lead to bundling. That threshold is $350,000 and the micro-purchase threshold is $15,000, both effective October 1, 2025 under FAC 2025-06. Guides still printing $250,000 and $10,000 aim at the wrong lines.
It has to answer your question by name. FAR 10.002(b)(1)(vii) makes the buyer determine whether small business concerns can meet the need at fair market prices, FAR 10.001(a)(3)(viii) makes them use the answer to decide whether FAR Part 19 applies, and FAR 7.105(b)(1)(v) carries it into the acquisition plan.
Which text your buyer is working from depends on who they work for. Under the Revolutionary FAR Overhaul deviations agencies follow today, market research stays in Part 10 and only the numbering moves, so the duty at FAR 10.002(e) becomes 10.001(e). Thirty-eight agencies have adopted a Part 10 deviation and thirty a Part 19, per acquisition.gov’s deviation guidance. A proposed rule published June 23, 2026 goes further, marking Part 10 removed and reserved and relocating market research to a new Subpart 7.2. Comments closed July 23 and nothing is final. The codified FAR governs everywhere a deviation does not, so two buyers can apply different texts on the same Tuesday.
The screens a buyer actually opens
Drop one belief first, because it costs firms effort. The public entity search on SAM.gov does not filter by NAICS code or by socioeconomic status. Signed out you get keyword, entity name or UEI or CAGE, location, and status. The record behind it does carry your NAICS codes with SBA’s small-business indicator, per GSA’s entity API. The screen will not sort a market on them.
The screen that will is the SBA Small Business Search, formerly DSBS. Memorize its advanced search rail, the shape of every buyer query: Location, SBA certifications, NAICS, Keywords, Business type, Last updated, and More filters, holding bonding levels, quality standards, and a switch to exclude expired SAM.gov registrations. The overhauled Part 19 names that tool and its address at 19.105-1 and 19.108-2, while the codified FAR at 10.002(b)(2)(ix) still says “Dynamic Small Business Search.”
Award history moved as well. The FPDS.gov public site, its login and ezSearch were decommissioned on February 24, 2026, and the data sits in the Contract Awards domain of SAM.gov, filterable by keyword, agency and legal business name, nothing else. Coverage reaches every unclassified contract action above the micro-purchase threshold, matching FAR 4.606(a)(1). An account is required now.
If a schedule can meet the need, the search may never reach the open market. FAR 8.402(d)(1) makes GSA eBuy the electronic quotation system and one medium for the fair notice FAR 8.405-2 and FAR 8.405-3 require, and FAR 8.402(c)(2) makes GSA Advantage! a catalog searched by stock or part number. Under FAR 8.405-5(a) the FAR Part 19 preferences are not mandatory there. One channel has no search box: FAR 19.202-2(a) sends the buyer to the agency small business specialist and the SBA procurement center representative.
The filter order, and where you drop out
Code first. FAR 19.102(b)(1) permits one NAICS code per solicitation, contract, and task or delivery order, assigned to the industry that best describes the work’s principal purpose. It sets the size standard, frozen as of the solicitation date by FAR 19.102(c)(1) and appealable only under FAR 19.103. The code is a gate, not a preference. The filter returns only firms SAM calculates as small for it, and the panel carries a checkbox reading “Only search primary NAICS.” Tick it and firms holding the code second are gone. We wrote separately about primary codes.
Status second. Above the simplified acquisition threshold, FAR 19.203(c) makes the buyer consider 8(a), HUBZone, SDVOSB and WOSB before a plain small business set-aside, with no precedence among them under FAR 19.203(a). FAR 19.203(d) sends them to the research and the agency’s progress against statutory goals: 15 U.S.C. 644(g)(1)(A) sets 23 percent of prime contract value to small business, 5 percent each for service-disabled veteran-owned, women-owned and small disadvantaged firms, 3 percent for HUBZone. The certifications filter runs on SBA records. The Business type filter runs on self-attestations SBA warns “are not vetted by SBA.”
Words third, big enough for its own section below. None of this order is habit. The regulation fixes every step of it.
Geography fourth, on one address. Filtering goes finer than states, down to zip codes, counties, congressional districts and metropolitan statistical areas, all off the single primary address in your registration. Crews that travel are invisible unless your narrative says so.
Evidence fifth, where a listed firm still loses. GAO sustained a protest in Knudsen Systems, Inc., B-422433.2 in August 2024, holding that research must address “not only the existence of small businesses that might submit proposals, but also their capability to perform the contract.” Buyers who know it hunt for performance history: contract number, dates, value, a callable reference. A blank profile gives them nothing to use.
Then the count. Market Insights returns how many firms in the result set hold each SBA certification and SAM business type, stamped with the date and time it ran. SBA’s own example: Texas, NAICS 236115, nine certified women-owned small businesses, March 12, 2025 at 1:19PM CDT. That number goes in the memo.
“When I ran those searches for an agency, filtering without typing anything brought the list back in no particular order, so I read whatever sat in front of me. Then I exported the set and mailed the addresses in it. If your registration email went to a mailbox nobody opened, I found you and lost you in the same click.”
Keywords are where most firms lose
Buyers search in the language of their requirement, which is the language of the solicitation, the statement of work, and the incumbent contract. It is rarely the language of your industry’s marketing. If your profile says “innovative solutions” where the buyer types “grounds maintenance,” you have opted out of the search.
Two paths reach your words, and they differ. The Keywords filter reaches terms in either your keywords list or your capabilities narrative, with a toggle for OR or AND. The search bar reaches five fields only: business name, doing-business-as name, capabilities narrative, UEI and CAGE code, ranked in that order. Your keywords field is invisible to it. Stuff the keywords, write a vague narrative, and one path reaches you while the other cannot.
There is no rank to win either. By SBA’s own documentation, a filtered search with nothing typed in the search bar comes back sorted randomly, and cannot be sorted by relevance. The job is membership in the set, then legibility once the profile is open.
Here is the rewrite that changes the outcome. Before: “A veteran-led firm delivering innovative, turnkey exterior asset solutions.” After: “Grounds maintenance and landscaping services for federal and institutional campuses under NAICS 561730. Mowing, edging, seasonal plantings, irrigation inspection and repair, tree and shrub pruning, snow and ice removal. Twelve crews, self-performed. Eight years of continuous grounds maintenance on a 340-acre campus.”
The keywords list changes the same way. “Exterior solutions, asset management, sustainability” becomes “grounds maintenance, landscaping, mowing, edging, irrigation repair, snow removal, campus grounds.” The company did not change. It became findable.
One search, start to finish
A regional facilities office needs grounds maintenance at a federal campus: mowing, edging, seasonal plantings, irrigation repair, snow and ice removal. Estimated value $600,000 over a base year and four options. Above $350,000, so FAR 10.001(a)(2)(ii) requires research first and FAR 19.203(c) puts the socioeconomic programs ahead of a plain set-aside.
The contracting officer assigns 561730, Landscaping Services, under FAR 19.102(b)(1). One code, not two. In the SBA directory they put 561730 in the NAICS filter, Location on the state, SDVOSB under certifications because the office is short against the 5 percent goal, and the requirement’s nouns in Keywords: grounds maintenance, mowing, irrigation repair, snow removal. Then Last updated to the past year, exclude expired registrations, open Market Insights.
Now a firm that should obviously be on that list. SDVOSB certified, twelve crews, eight years of campus grounds work for a state university system, registration active.
It drops at the code, because the owner listed 561730 as a secondary NAICS while the primary still reads 238990 from the hardscaping years. One checkbox removes it. It drops at the words, because the narrative sells exterior asset solutions and none of the buyer’s four nouns sit in either searched field. It drops at the clock, because SAM was updated eleven days ago. Survive all three and it can still drop at the read: twelfth in a random order, performance history empty, no capability statement uploaded.
When the buyer cannot find you
If the count comes up thin, the buyer publishes. Notices go to SAM.gov as the governmentwide point of entry under FAR 5.201(d), and a sources sought carries notice type code r in GSA’s opportunities API. For research and development, FAR 5.205(a) requires the title “Research and Development Sources Sought.” Under FAR 15.201(e) a request for information draws responses that are not offers, in no set format.
Nobody has to post one. FAR 10.002(b)(2) lists techniques a buyer may use, not must, and FAR 10.001(b) limits the ask to the minimum information necessary. That is why these notices arrive numbered and short, and why a brochure fails them.
A responsive reply answers the numbered questions in order. It states your UEI, CAGE code, size status under that NAICS code and current certifications, with contract-level past performance and a reference the buyer can call. It lands in the contract file inside the set-aside record FAR 4.803(a)(6) requires.
What the memo has to conclude
The codified rule of two is really two rules. FAR 19.502-2(a) covers buys above the micro-purchase threshold but not above $350,000: set aside unless there is no reasonable expectation of offers from two or more responsible small business concerns competitive on price, quality and delivery. FAR 19.502-2(b) covers everything above that: set aside when at least two such offers and award at fair market prices are reasonably expected.
At an agency running the overhauled Part 19, that collapses into one test at 19.104-1(a) above the micro-purchase threshold, and 19.104-1(b)(1) makes the buyer document the reason when a contract is not set aside. At the order level, 19.111-2(a)(2) makes the decision discretion, not a basis for protest.
Either way it is a reasonable-expectation test, not a promise. Answering a sources sought does not produce a set-aside and two answers do not compel one. It puts your firm inside the count the determination rests on.
What firms get wrong, and why it feels right
Registering in SAM.gov feels like arriving. The listing rules are mechanical instead. The SBA directory is a subset of SAM’s database: active registration, a UEI, purpose of registration set to “All awards,” entity structure among four permitted values, no tax-exempt entities. You appear only for codes where SAM indicates you are small.
Ticking “No Public Display” feels prudent too. It hides you from search results and from having a public profile page, and only current or former SBA certificate holders stay public anyway.
Leaving optional fields blank feels harmless, since SAM already holds your data. SAM supplies the skeleton: name, UEI, CAGE, address, NAICS codes, business types, registration status. The fields that persuade come from you through SBAConnect: capabilities narrative, keywords, capability statement, bonding levels, quality standards, principals, performance history. Three are buyer-facing filters.
Fixing the record the week a solicitation drops feels like good timing. SBA’s guide on showing up in search results puts a SAM.gov change at up to 10 business days to process, then 24 to 48 hours to reach the directory. FAR 10.002(b)(1) meanwhile lets a buyer reuse research from within 18 months of a task or delivery order award. And Last updated removes stale profiles outright.
What to do this week
The one that cannot wait is the primary code, since a secondary NAICS vanishes the moment a buyer ticks one box. That edit runs through SAM.gov and starts the processing clock. Those same fields cause most of the registration failures we get called in to repair.
The best test is the one we run for clients: build the filter set a buyer in your codes would plausibly use, run it, then read your own record from inside the result list.
This article covers the search pointed at you. The same data supports the one you run the other way, covered in finding the offices that already buy what you sell. Every step above is an indexing problem. You are not persuading anyone yet. You are making sure the people with money and a requirement can find you when they go looking.