Guides / How-to

Can you subcontract a federal janitorial contract?

Often yes, in part. The solicitation decides whether you may subcontract, how much of the work someone else can perform, and whether the contracting officer has to agree first. On a small-business set-aside, the prime generally has to keep a substantial share.

The prime stays responsible

The government holds the prime contractor responsible for performance, staffing, and the labor standards, even when a subcontractor does the cleaning. A subcontract does not move the contract to the subcontractor. If you are the prime, you still need a way to supervise the buildings. If you are the subcontractor, your customer is the prime, under whatever the subcontract says, and the prime's federal clauses often flow down.

Limits on a small-business set-aside

For service contracts, SBA's limitations on subcontracting (13 CFR 125.6) generally say the prime may not pay more than half of the amount the government pays the prime to firms that are not similarly situated. A similarly situated subcontractor has the same small-business program status as the prime and is small for the work it is performing. The regulation defines that term, including which size standard applies. Work that firm performs can count as work the prime performed. Read the section before you split the work.

That limit applies to small-business set-asides and certain other small-business contracts covered by 13 CFR 125.6. A full-and-open janitorial contract can allow more subcontracting, or it can restrict it. The clause in that solicitation is the one that matters.

Janitorial work under NAICS 561720 is a service. Use the services rules, not the rules written for supplies. Confirm the NAICS code on the notice. Which set-aside you are in is covered in how set-asides work for small cleaning and landscaping firms.

The solicitation's subcontracting clause controls if it differs from the summary above. The federal acquisition rules are being rewritten under the FAR overhaul, and agencies have adopted new text on different dates. Do not carry a clause from the last contract into this one.

Consent. Many contracts require the contracting officer's consent before you subcontract, or they require you to name major subcontractors in the offer. The solicitation states whether consent is required and at what point. Do not assume a dollar cutoff you remember from a different contract.
Subcontracting plans. Firms that are not small are often required to submit a small-business subcontracting plan. Small-business primes are often not required to submit that plan. The solicitation will say which applies. SBA explains the plan in its guide to prime and subcontracting.

Wage rules reach the subcontractor

Service Contract Labor Standards generally apply to subcontractors that perform the covered service, not only to the prime. Put the wage determination into the subcontract and price the quote at or above those rates, including health and welfare if the determination lists it. How to read that fringe is in how to price health and welfare in a cleaning bid.

The Department of Labor's service contracts page and 29 CFR Part 4 are the official starting points. The determination attached to the solicitation still sets the rates for that bid.

Finding subcontract work

Read SBA's subcontracting guide, linked above, and the directory of prime contractors with subcontracting plans.
Use USAspending and SAM.gov award notices to see who holds large facilities contracts near you. How to find incumbent prices walks through those records. An award amount is not a promise that the prime needs a cleaning subcontractor.
On a bid you will prime, get subcontractor quotes before you submit, and confirm those firms can clear the building's security rules. You still have to meet the performance limit after award, not only on proposal day.

If the past-performance section is the reason you want a partner, read how to bid with no federal past performance before you assume the partner's contracts will count.

General information from the Bid Brief team, not legal or contracting advice. The solicitation, its subcontracting clause, and its amendments control. We aren't affiliated with SBA, the Department of Labor, SAM.gov, or any government agency. Last reviewed Nov 5, 2026.

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