3 min read
How to buy custom software under the $15,000 micro-purchase threshold
A contracting officer can put small software work on a purchase card with no competition required. Here is what the threshold actually permits, where the limits bite, and what to ask a vendor for.
Most small software work inside a federal agency never needs a solicitation. It needs a purchase card, a quote, and someone willing to read FAR Part 13.
The micro-purchase threshold is $15,000 for supplies and services as adjusted effective October 1, 2025. Below it, a contracting officer or an authorised purchase cardholder may buy without obtaining competitive quotations, provided they consider the price reasonable. That is the whole mechanism. It is not a loophole and it is not a workaround — it is the acquisition method the FAR designed for exactly this situation.
It is also badly underused for software, because most people assume any software purchase implies a procurement cycle measured in months.
What the threshold actually permits
Three things are worth being precise about.
No competition is required. FAR 13.202 states micro-purchases may be awarded without soliciting competitive quotations if the price is considered reasonable. "Reasonable" is a judgement the cardholder makes and documents — often by reference to a published rate, a prior purchase, or a quick market check. It is not a formal price analysis.
Purchases should be distributed equitably. The same section directs that micro-purchases be distributed among qualified suppliers where practicable. In practice this means an agency should not route every micro-purchase to one vendor by habit, which is genuinely good news if you are the vendor nobody has tried yet.
Splitting a requirement to stay under the ceiling is prohibited. This is the constraint people get wrong. You may not take a $40,000 requirement and break it into three purchases. The test is whether the work is a single requirement, not whether the invoices are separate. A discrete, bounded piece of work that stands on its own is fine. A phased delivery of one larger system is not.
Where it fits, and where it doesn't
The threshold suits work that is genuinely small and genuinely finished at the end of it:
- A defined integration between two systems the agency already runs
- Accessibility remediation on an existing application
- A reporting or data-extract tool replacing a manual process
- A fixed-scope assessment — a security review, a modernization options paper
- A short block of maintenance on a system with no current support arrangement
It does not suit anything open-ended, anything that will obviously need a follow-on phase, or anything where the requirement is still being discovered. If the honest answer is "we don't yet know how big this is," a micro-purchase is the wrong instrument and using it anyway creates a splitting problem later.
Above $15,000, the next step up is simplified acquisition procedures, which run to $350,000 for commercial products and services. Still far lighter than full competition, but quotes are expected.
What to ask a vendor for
If you are the buyer, the quote should let you close the file without a second email. Ask for:
| Item | Why it matters |
|---|---|
| UEI and CAGE | You need both to verify registration and to pay |
| Active SAM.gov registration | Confirm it is active and check the expiration date |
| NAICS code | 541511 for custom programming; confirms size standard |
| PSC code | Most CO searches are by PSC, not NAICS |
| Purchase card acceptance | If they cannot take the card, the mechanism does not work |
| Fixed price and a defined deliverable | Not an hourly estimate — a scope with an end |
That last row does most of the work. A micro-purchase wants a fixed price against a scope you can point at. An hourly rate with a range attached invites exactly the scrutiny the threshold is meant to avoid.
The end of the fiscal year
The federal fiscal year closes September 30, and September is consistently the heaviest spending month of the year as agencies obligate remaining funds. Micro-purchases move fastest of anything available, because there is no solicitation period to run. If you are a buyer with funds to obligate and a small piece of work that has been waiting, this is the instrument. If you are a vendor, this is the window where the answer to "how quickly can you turn a quote around?" decides the outcome.
What we do
We are registered in SAM.gov, we hold an active UEI and CAGE, we work under NAICS 541511, and we accept the Government Purchase Card. Our capability statement carries the identifiers a contracting officer needs to verify us and buy, on one page, without asking us for anything first.
If you have a bounded piece of software work and funds that need to move, we quote within one business day.
