SDVOSB Certification Through SBA VetCert After the VA CVE Transition

Service-disabled veteran-owned small business (SDVOSB) status is no longer something a firm can claim on its own for set-aside work. Since January 1, 2023, the U.S. Small Business Administration (SBA) has held sole authority to certify SDVOSBs through its Veteran Small Business Certification (VetCert) program, codified at 13 CFR Part 128. Self-certification for restricted awards has been eliminated. A firm must now hold an active SBA certification to compete for an SDVOSB set-aside.

This article explains why certification authority moved from the Department of Veterans Affairs to SBA, the two self-certification cutoffs that closed the old regime, how previously verified firms transitioned, what the VetCert eligibility standard requires, how to apply, and what the change means for prime contractors screening SDVOSB subcontractors. For the full framework surrounding set-aside eligibility, read the SDVOSB Federal IT Contracting Guide.

Why Certification Moved From VA CVE to SBA

Before 2023, two parallel systems governed SDVOSB status. The Department of Veterans Affairs, through its Center for Verification and Evaluation (CVE), formally verified firms for VA set-asides under the Vets First program. For every other federal agency, a firm could simply self-certify its SDVOSB status in the System for Award Management (SAM) and represent that status on offers. The result was an uneven standard: a firm rigorously vetted for VA work sat alongside firms that had never been examined by anyone.

The National Defense Authorization Act for Fiscal Year 2021 closed that gap. It directed the consolidation of veteran small business certification under a single authority and transferred the function from VA to SBA. SBA implemented the mandate through a final rule published November 29, 2022, establishing the Veteran Small Business Certification Program at 13 CFR Part 128. The transfer took effect January 1, 2023. From that date, one office and one standard govern both VOSB and SDVOSB certification across the entire federal government, and the SBA VetCert portal became the single point of application.

The Two Self-Certification Cutoffs That Matter

Procurement officers and firms frequently conflate two distinct deadlines. They are separate, and each applies to a different category of work.

Prime set-asides and sole-source awards. The regulations provided a one-year grace period following the January 1, 2023 transfer. Self-certification for SDVOSB sole-source and set-aside prime awards ended January 1, 2024. A firm that had submitted a complete VetCert application on or before that date was permitted to continue relying on its eligibility while SBA processed the application, but a firm with no application on file lost the ability to compete for restricted SDVOSB prime work.

Subcontracting and agency goaling. A separate cutoff governs whether a firm counts toward an agency's SDVOSB contracting goals or a prime's SDVOSB subcontracting commitment. Under the final rule published June 6, 2024, the self-certification grace period for subcontracting and goaling purposes ran through December 22, 2024. After that date, only SBA-certified SDVOSBs are credited toward those categories. The SBA veteran contracting page confirms that all veteran firms had to be certified before December 22, 2024 to remain eligible for goaling and subcontracting credit.

The practical takeaway: as of today, there is no lawful path to compete for an SDVOSB set-aside, or to be counted as an SDVOSB subcontractor for goaling credit, without an active SBA certification.

How CVE-Verified Firms Transitioned

Firms already verified by VA's CVE before the transfer date were not required to reapply immediately. They were deemed certified by SBA for the remainder of their existing three-year term of eligibility. To prevent a wave of expirations in the program's first year, SBA extended, by up to one year, the eligibility of firms whose deemed terms would otherwise have lapsed during 2023. When a deemed term expires, the firm files for recertification through the VetCert portal on the same footing as a new applicant.

The transition mechanism means a firm's certification history did not reset, but its renewal obligation did shift. Contracting officers confirming a subcontractor's status should verify the current certification and its expiration date in the certification record rather than relying on a legacy CVE reference or a stale SAM representation.

What the VetCert Eligibility Standard Requires

The eligibility requirements in 13 CFR Part 128 Subpart B mirror the substantive tests that governed CVE verification, applied uniformly. To qualify as an SDVOSB, a concern must satisfy four core conditions:

• Service-disabled veteran status. One or more service-disabled veterans must own the concern. Disability status is established through VA documentation. For a veteran with a permanent and severe disability, a spouse or permanent caregiver may satisfy the control test.
• Ownership. One or more service-disabled veterans must directly and unconditionally own at least 51 percent of the concern. Ownership through intervening entities is scrutinized to confirm the veteran holds the ultimate beneficial interest.
• Control. Service-disabled veterans must control both the long-term decision-making and the day-to-day management of the concern. The veteran must hold the highest officer position and possess the managerial experience needed to run the business. Provisions in operating agreements or bylaws that let non-veterans block ordinary business decisions can defeat the control test.
• Small business size. The concern must qualify as small under the size standard corresponding to its primary North American Industry Classification System (NAICS) code.

A VOSB certification uses the same ownership, control, and size tests without the service-disability requirement. A firm certified as an SDVOSB is simultaneously eligible for VOSB set-asides.

How to Apply Through VetCert

Application runs entirely through the SBA VetCert portal. The process follows a predictable sequence:

1. Confirm the prerequisites. The firm must have an active registration in SAM and a Login.gov account tied to an authorized owner. Size status should be validated against the primary NAICS code before filing.
2. Assemble the documentation. Typical submissions include organizational documents (articles, operating agreement or bylaws, and any amendments), ownership and equity records, governance and signatory authority evidence, and the veteran's VA disability documentation.
3. Submit and respond to SBA review. SBA examines the filing against the Subpart B tests and may request clarification. Complete, internally consistent governance documents shorten the review; ambiguity in control provisions is the most common source of delay or denial.
4. Receive the determination. An approved concern receives a three-year certification, reflected in the certification record that contracting officers and primes rely on for verification.

Because ownership and control drive most adverse decisions, firms with complex cap tables, outside investors, or shared-management arrangements should reconcile their governing documents with the Subpart B requirements before filing rather than after a deficiency notice.

Maintaining Certification and Recertifying

Certification is not a one-time event. Under 13 CFR 128.306, a certified concern must notify SBA of any change in ownership or control that could affect eligibility, and it must attest to continued eligibility during the term. SBA may conduct a program examination at any time and will review the concern at recertification. Material changes, such as a new controlling owner, a shift in the highest officer position, or growth past the applicable size standard, can end eligibility before the three-year term runs.

A firm should treat recertification as a rolling obligation, tracking its expiration date and updating governance records as the business evolves. Letting a certification lapse creates an eligibility gap that disqualifies the firm from restricted awards until a new determination issues.

What This Means for Primes Screening SDVOSB Subs

For a prime contractor building a team, the shift to mandatory SBA certification simplifies due diligence and raises the stakes of getting it wrong. Under FAR Subpart 19.14, the SDVOSB status a prime relies on for subcontracting or goaling credit must be a current SBA certification, not a self-representation. A prime that credits an uncertified firm toward an SDVOSB subcontracting commitment risks losing that credit and, on protest, the standing of the award itself.

The practical control is straightforward: verify the subcontractor's active SBA certification and expiration date at teaming and again at award, and require the sub to notify the prime of any change in certification status during performance. Pairing that verification with the work-share and limitations-on-subcontracting analysis covered elsewhere in this cluster gives the prime a defensible compliance record. See the SDVOSB Joint Venture Rules Under 13 CFR 125.18 for how certified status interacts with joint venture structures, and the SDVOSB Set-Asides and the Capability Gap for how certification supports capability positioning.

The Bottom Line

The SDVOSB program has moved from a mixed self-certification and CVE-verification model to a single, government-wide certification standard administered by SBA under 13 CFR Part 128. Self-certification ended for prime set-asides on January 1, 2024 and for subcontracting and goaling credit on December 22, 2024. Firms competing for restricted work, and primes crediting them, now operate on one verifiable standard. The firms that treat certification and recertification as a continuous obligation, rather than a one-time filing, keep an uninterrupted eligibility record and a clean position on any protest.