No Past Performance? What Actually Counts Toward Your First Government Contract
Almost every owner who reads a solicitation for the first time hits the past performance section and quietly closes the tab. You need contracts to prove you can do contracts, and you have no contracts. It reads like a locked door with the key on the other side. It isn't one, and the rule that says so is sitting in the FAR in plain language.
Here is the misunderstanding at the center of it. Past performance does not mean “federal contracts you have already won.” It means relevant work, recently done, that somebody outside your company will vouch for. Federal contracts are one source of that. They are not the definition.
Once you see it that way, the question stops being “how do I get past performance” and becomes two much more answerable ones: what do I already have that counts, and what is the fastest legitimate way to add to it.
The FAR rule nobody quotes at you
Start with the sentence that does the work. FAR 15.305(a)(2)(iv): “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.”
Read the second half again. Not unfavorably. An empty past performance record is not a low score. It is a neutral one, and an evaluator who marks you down for it is doing something the FAR does not allow. Bid-protest decisions have gone the same way: excluding a firm from the competitive range purely because its past performance is unknown has been found to be improper unfavorable treatment.
The same section has a second sentence worth your time. The solicitation is required to describe how it will evaluate offerors with no relevant performance history. So the answer for any particular bid is printed in the bid documents. Go and read Section M, or the evaluation factors, before you decide you are disqualified. You are usually reading a requirement that somebody else invented for you.
The honest flip side, because it matters: neutral is not a free pass. It means the decision lands entirely on your technical approach and your price. If those are thin, neutral past performance will not save you. What it does is keep you in the competition long enough for the rest of the proposal to be read.
What already counts, and what “relevant” actually means
Evaluators are asking three things about every reference you submit: is it relevant, is it recent, and how did it go. Nothing in that list says federal.
Commercial contracts count. State, county and city work counts, and counts well, because public procurement runs on the same bones as federal procurement — scope of work, deliverables, invoicing against a schedule, somebody with authority signing off. A nonprofit or school district contract counts. Work your key personnel performed at a previous employer can often be submitted, with the right framing.
Relevance is where most first-time bidders get it wrong, because they read it as “same industry” when the government reads it as similar in scope, magnitude and complexity. Three $40,000 jobs are not automatically a substitute for one $400,000 job, and a solicitation will often say how close it expects the match to be. If yours are smaller, say so directly and explain what makes them comparable. Evaluators forgive a modest reference described accurately. They do not forgive one dressed up as something it isn't, and they check.
The 2022 rule that turned subcontract work into a real record
This one is genuinely useful and still surprisingly little known. Under 13 CFR 125.11, a small business can use the experience and past performance of a joint venture it was a member of. And for first-tier subcontract work on a prime contract carrying a subcontracting plan, you can require the prime to give you a written performance rating.
The mechanics are specific, so get them right. You request the rating within 30 days after the prime contract's period of performance ends. The prime has 15 calendar days to respond, using the standard scale — exceptional, very good, satisfactory, marginal, unsatisfactory — and covering things like technical quality, cost control, schedule and management relations. When you later bid as a prime, the contracting officer is required to consider it.
The practical move is to stop treating that as paperwork you chase at the end. Put the rating obligation in the subcontract agreement when you sign it, with the name of the person who will write it. Primes are not being obstructive when they go quiet on this — the project manager who knew your work has moved on, and there is nobody left to ask.
CPARS is the file the government keeps on you
Once you do have federal work, your record stops being something you assemble and becomes something the government maintains. That is CPARS, the Contractor Performance Assessment Reporting System, and evaluators pull from it directly. You cannot read your competitors' evaluations. You can read your own.
Two numbers from FAR 42.1503 are worth writing on the wall. You get 14 calendar days from notification to submit comments, a rebutting statement or additional information on an evaluation. And agencies use CPARS information within three years of completion of performance — six for construction and architect-engineer work.
Put those together and the stakes are obvious. A mediocre evaluation you let pass unanswered is not a bad week. It is a document that shapes how you are scored on every bid for the next three years, and the two weeks in which you could have added context are the only two weeks you get. In the other direction, a strong record ages out on the same schedule, so a firm that wins one good contract and then stops bidding is back to neutral sooner than it expects.
Bid where past performance is not the deciding factor
The fastest way out of a neutral rating is a contract small enough that the neutral rating does not matter much.
Below the micro-purchase threshold — $15,000 under the current FAR 2.101 definitions — agencies have enormous latitude and often need nothing more than a quote. Below the simplified acquisition threshold of $350,000, procurement is deliberately lighter-weight, and those buys are reserved for small business. That is a wide band of real work that does not require a proposal volume with five past performance references in it.
State and local is the other on-ramp, and for most owners it is the better one. The dollar values are smaller, the competition is thinner, the buyer is often within driving distance, and a completed city contract is a reference a federal evaluator will recognize. We walk through the whole sequence in how to bid on government contracts as a small business.
Where we come in
Past performance narratives are one of the harder pieces of proposal writing, because the job is not to describe the project. It is to prove relevance to this solicitation, in the format that solicitation demands, without overstating anything. The same three contracts can read as a strong record or a weak one depending entirely on how they are framed against the evaluation criteria.
That work is included in our proposal and RFP writing, which runs on contingency: nothing upfront, 10% of awarded contract value, and nothing owed if the bid does not win. Opportunity research, technical writing, past performance narratives, compliance review and submission are all inside that fee. If you have no federal record yet, we would rather aim you at the winnable small bids first than write you a heroic proposal for something you cannot yet credibly claim.
Two adjacent things help more than owners expect. A one-page capability statement at $197 is where your past performance has to survive a ten-second read by a contracting officer — and it is the document that gets you subcontracting conversations, which is how the record starts. And bid and opportunity monitoring at $297 a month exists because the small, low-past-performance-weight solicitations are exactly the ones nobody has time to go looking for. It is included free alongside a proposal engagement.
This is probably not a fit if…
You want past performance you did not earn. There is a market in creative reference framing, and we are not in it. Misrepresenting past performance is not a presentation choice, it is a false statement on a federal proposal, and the consequences run well past losing the bid.
You are chasing a large recompete as your first move. If an incumbent has been performing the work for five years with strong CPARS ratings, a neutral rating plus a good technical volume is not usually enough. That is not pessimism, it is where the evaluation weight sits. Build a record on smaller work first.
You are not registered in SAM yet. Past performance is a later problem. Nothing can be awarded to an entity that is not registered and active, so start with SAM.gov registration at $597 and come back to this once that is live.
If none of those apply, book a free 30-minute call and bring a list of the last five jobs you did for anybody. We will tell you honestly which of them a federal evaluator would count, and what the nearest winnable bid looks like.