Long-Term Contract Recertification Windows
Eligibility you certified at award does not freeze for the life of a long-term vehicle. For contracts that run more than five years, the rules require a concern to recertify its size and socioeconomic status at set points so the agency knows whether it can still count the award toward small-business and SDVOSB goals. There are also event-driven recertification triggers — a merger, acquisition, or novation can require recertification on its own clock, regardless of where you are in the contract term.
The Deadline
Recertify near year five & at each option
What Starts the Clock
Holding a long-term contract (more than five years) or a triggering event such as an option exercise, merger, acquisition, or novation.
Who Has To Track This
- SDVOSBs holding IDIQs, GWACs, BPAs, or other contracts longer than five years
- Firms approaching an option-exercise decision on a long-term vehicle
- Owners closing a merger, acquisition, or novation during performance
Key Dates
- ~120 days before year-5 end
Recertify size and status near the end of the fifth year of a long-term contract.
For contracts longer than five years, a concern generally must recertify its size and status no more than 120 days before the end of the fifth year (13 CFR 121.404(g); 13 CFR 125.18(e) for SDVOSB).
- ~120 days before option
Recertify before each option exercised after that point.
After the fifth-year recertification, the firm generally recertifies again within 120 days before the exercise of each subsequent option, so the agency has a current status determination for each ordering period.
- Within ~30 days of the event
Recertify after a merger, acquisition, or novation that affects status.
A merger, acquisition, or novation can require recertification within a short window after the transaction (commonly 30 days under 13 CFR 121.404(g)), independent of the contract's option schedule. Confirm the exact trigger and window for your transaction.
If You Miss It
- Recertifying as other-than-small (or no longer SDVOSB) can stop the agency from counting future orders toward its small-business and SDVOSB goals.
- Missing a required recertification can create compliance findings and complicate option exercises.
- An unreported status-changing transaction can surface in a later eligibility examination or protest.
Frequently Asked
When does an SDVOSB have to recertify on a long-term contract?
For contracts longer than five years, a firm generally recertifies its size and status no more than 120 days before the end of the fifth year, and again within 120 days before the exercise of each subsequent option. Certain events — a merger, acquisition, or novation — can also trigger recertification on their own short timeline (13 CFR 121.404(g); 13 CFR 125.18(e)).
Does recertifying as 'other than small' end my contract?
Not necessarily — the firm can usually continue performing the existing contract, but the agency may no longer count orders against it toward small-business and SDVOSB goals once it recertifies as other-than-small. The practical effect is on future set-aside crediting and on the firm's eligibility for new small-business work.
Do I have to recertify after a merger or acquisition?
Yes, if the transaction affects the firm's size or status. A merger, acquisition, or novation can require recertification within a short window (commonly 30 days) after the event under 13 CFR 121.404(g), separate from the contract's option schedule. Confirm the exact trigger and timeframe for your specific transaction.
Primary Sources
- 13 CFR 121.404 — When is the size status of a concern determined?
- 13 CFR 125.18 — SDVOSB program requirements (recertification)
Planning aid, not legal advice. SDVOSB rules are still settling after the 2023 transfer of certification to the SBA, and several of these windows are stated in business days or run from a procurement-specific event — verify the exact deadline against the cited authority, your solicitation, and your contracting officer before relying on it.
Change log (1)
- LaunchedPublished the compliance deadline reference covering the SAM.gov annual renewal, the three-year VetCert certification term, long-term-contract recertification windows, the SDVOSB status-protest filing deadline, and the date set-aside eligibility is measured — each with an ItemList of key dates plus FAQPage, Dataset, and BreadcrumbList structured data, primary-source citations, and cross-links into the how-to guides, regulation explainers, compliance checklists, glossary, and FAQ.