A business owner sees a federal solicitation asking for past performance and assumes the opportunity is off limits. The company has delivered good work for commercial customers, but it has never held a federal prime contract.
That is not automatically a disqualification.
The real questions are what the solicitation allows, how the agency evaluates relevance, and whether your evidence supports the work being purchased. Some opportunities fit a business with commercial experience. Others require qualifications or experience you do not yet have.
Your job is to distinguish between those situations before investing in a proposal.
Separate experience from past performance
These terms are often used synonymously, but sometimes a solicitation asks for both experience and past performance as separate parts of your proposal. When it does, understand the distinction: experience is what work you have done; past performance is how you performed on that work.
Experience: What work did you do?
Experience establishes the work you have performed and its relevance to the proposed requirement. Did you perform similar tasks? At what scale? Under what conditions?
Follow the solicitation’s instructions and include important project details such as:
- Project title.
- Dollar value.
- Date range or period of performance.
- Customer.
- Brief scope of work.
- Your company’s role and responsibilities.
These details help the evaluator understand what you actually delivered. They establish the substance of your experience, rather than simply asserting that you have worked in the industry.
Past performance: How well did you do it?
Past performance addresses the quality of your execution. For the same project, explain:
- Overall customer satisfaction.
- Whether you completed the work on time.
- Whether you performed within the budget.
- Any issues or delays and how you addressed them.
- Situations that required a response, the actions you took, and the results.
- Any letters of recommendation received or other permitted evidence of customer satisfaction.
Do not stop at listing the project’s scope when the agency is asking how you performed. Likewise, a positive recommendation does not replace the project details needed to establish relevant experience. If the proposal requests separate sections, organize your evidence accordingly and follow any instructions for supporting documents.
A solicitation may evaluate these separately or combine aspects of them. It may also distinguish corporate experience from the experience of proposed personnel.
That distinction matters for a new business. A founder may have years of relevant employment experience while the company itself has no completed contracts. The founder’s background can be valuable, but it is not automatically the company’s past performance.
Use each piece of evidence in the category the solicitation permits. Do not blur ownership of the work to make your record look larger.
Check what the solicitation actually accepts
Before drafting project descriptions, identify the rules for the submission and evaluation.
Look for:
- Whether commercial, state, local, or federal projects are acceptable.
- The required number of examples and applicable recency period.
- How the agency defines relevant scope, size, and complexity.
- Whether ongoing projects are acceptable.
- Whether subcontractor, key-personnel, or predecessor-company records may be considered.
- Required questionnaires, references, forms, and page limits.
For negotiated acquisitions covered by FAR Part 15, an offeror without relevant past performance generally may not be evaluated favorably or unfavorably on past performance. That does not mean every new business qualifies for every competition or receives the same overall evaluation as an experienced competitor.
Separate experience requirements, technical factors, and other conditions can still matter. Different acquisition procedures may also use different approaches.
If the instructions are unclear, submit a precise question before the question deadline. Ask whether a specific type of experience is acceptable rather than requesting a general explanation of past performance.
Choose relevance over name recognition
A recognizable customer is not necessarily your strongest example.
Suppose the government needs recurring maintenance across multiple occupied facilities. A smaller commercial project involving multiple locations, scheduled service, and strict access procedures may be more relevant than a larger one-time installation.
Compare potential examples against the actual requirement:
- Were the tasks similar?
- Was the staffing or production volume comparable?
- Did you manage similar locations, schedules, or technical constraints?
- Were inspection and reporting requirements comparable?
- Did your company perform the work directly or manage others?
Build a simple internal comparison table before choosing projects. This keeps you from selecting examples based only on revenue or customer prestige.
If an example is only partly relevant, explain the connection accurately. Do not call two projects identical because both involved the same broad industry.
Turn commercial projects into clear evidence
Commercial work does not need government-sounding language to become useful. It needs a clear description and supportable results.
For each permitted example, prepare the requested details, which may include:
- Customer name and authorized reference contact.
- Project dates and contract value, when requested and disclosable.
- Your company’s role and specific responsibilities.
- Scope, staffing, locations, and operating conditions.
- Evidence of quality, schedule performance, or customer acceptance.
- A concise explanation of relevance to the proposed contract.
Use a consistent structure: what the customer needed, what you performed, how you performed, and why it matters here.
Avoid unsupported claims such as “flawless execution” or “industry-leading service.” A documented delivery record or customer acceptance statement is more useful than a stack of adjectives.
If you describe a problem, explain the corrective action and result honestly. Credibility is more valuable than pretending every project was effortless.
Be precise about subcontract experience
If you performed work under another contractor, identify yourself as the subcontractor. Explain your portion of the work rather than claiming the entire prime contract.
For example, if your company handled one location under a nationwide program, describe that location and your responsibilities. The program’s total value is not your company’s performed value.
Where the solicitation allows subcontract experience, the prime contractor may be your best reference because it directly observed your performance. Confirm which reference information is required.
Do not imply that the government issued your company a performance rating when it evaluated only the prime. You can still provide useful evidence through documented deliverables, acceptance records, and authorized references.
Use personnel and teaming evidence correctly
A new company may propose an experienced project manager or team with a qualified subcontractor. That can strengthen an offer when the evaluation criteria permit consideration of those records.
Explain whose experience is being presented and what role that person or company will perform. The connection should be operational, not decorative.
If you rely on a subcontractor’s specialized experience, show how its proposed responsibilities relate to that experience. Confirm its commitment and comply with any required documentation.
Also check applicable set-aside rules and limitations on subcontracting. Building a team does not remove the prime contractor’s performance obligations.
An owner’s former employer project should be labeled as the owner’s individual experience, where allowed. Do not present the former employer’s contract as a contract held by the new business.
Prepare references before submission
A reference who does not respond can weaken an otherwise useful submission, depending on the evaluation process.
Contact references early. Confirm their current email address, phone number, willingness to participate, and knowledge of the work. Explain the expected questionnaire or contact process and any deadline.
You may remind them of accurate project details. Do not script an evaluation or ask them to support claims they cannot verify.
If customer confidentiality limits disclosure, address that before submission. Ask the contracting officer about acceptable handling through the solicitation’s process rather than assuming confidentiality excuses missing required information.
Handle a genuine gap strategically
Sometimes you do not have suitable examples. Say so accurately and follow the instructions for offerors without relevant past performance.
Then evaluate the rest of the competition. Can your technical approach, staffing, qualifications, and price support a credible offer? Or does a separate mandatory experience requirement make this a poor target?
If the gap is too large, build relevant evidence deliberately through commercial work, appropriate subcontracting, or smaller requirements that match your current capability. Keep records as you perform rather than trying to reconstruct them years later.
The objective is not to make a new business look established on paper. It is to show the evaluator exactly what you can support today—and pursue work where that evidence is enough to compete.
Derek's Unconventional Wisdom: You Do Not Need Two Years as a Subcontractor First
Very often in federal contracting, you are told that if you do not have direct past performance, you have to be a subcontractor for two years before you can pursue prime contracts. I want to be clear: that is absolutely not true as a blanket requirement.
Subcontracting is not necessarily a bad route. If that is the path you want to take, it can make sense. What I disagree with is presenting it as the only path, as though every new business has to serve a mandatory apprenticeship before it can submit its own offer to the government. A strategic choice and a requirement are two different things.
You can start a new business for the sole purpose of bidding on federal contracts, complete the required registration steps, and obtain a CAGE code without having performed work before. That does not make you qualified for every solicitation, and a CAGE code is not proof of capability. But a lack of prior work does not automatically close the door to competing as a prime contractor.
Choose a route that fits your actual starting point
If you have no direct past performance, I would focus on two routes rather than assume you need to spend two years somewhere else first.
The first is to pursue contracts that do not require past performance or experience. That means reading the actual submission and evaluation requirements—not assuming that every federal opportunity demands a portfolio of completed federal projects. You still need to meet the other requirements and present a credible plan for delivering the work. No past-performance requirement does not mean no responsibility to perform.
The second is to team with subcontractors and include their past projects where the solicitation allows it. You submit an offer to the contracting office that presents the proposed team, including those subcontractors and the relevant work they bring. Your company can be the prime even though another member of the team supplies experience the government is permitted to consider.
I am not talking about borrowing a company’s project list and pretending it belongs to you. Identify whose projects they are, explain what that subcontractor will do, and make sure its involvement is real. The proposal should show how the team will execute the requirement, not just how impressive the team looks on paper. You also have to respect the solicitation’s rules and any applicable limitations on subcontracting.
Build your own record through performance
The point of this strategy is to create a path to your own direct federal past performance. Once you win a prime contract and perform the work, you begin building a record your company can use on future bids, subject to those solicitations’ requirements. Winning creates the opportunity; execution creates the performance evidence.
I would treat documenting that work as part of running the contract. Keep track of what you delivered, whether you met the schedule and budget, how you handled problems, and what the customer said about the result. Those details become the substance of your next proposal.
My position is simple: subcontract because it fits your business strategy, not because someone told you there is a universal two-year waiting period. If your goal is to compete as a prime, choose opportunities and teammates that make that possible without misrepresenting your record.
Derek James
Derek James is the founder of GovKidMethod. By his 30th birthday, he had won 32 contracts worth over $15M for a small business across various U.S. federal agencies. Now he teaches small business owners how government contracting really works.
