Full and Open Competition

Full and open competition is the federal acquisition principle requiring agencies to allow all responsible sources an opportunity to compete for government contracts, ensuring the government receives best value through competitive market pressure.

What is Full and Open Competition?

Full and open competition is the default requirement for federal procurement under the Competition in Contracting Act (CICA) and FAR Part 6. Under this requirement, agencies must use competitive procedures that do not restrict who can submit a proposal or bid. The solicitation must be posted publicly on SAM.gov (for awards above $25,000), giving all qualified vendors the opportunity to compete.

FAR Part 6 recognizes seven exceptions that allow agencies to limit or avoid competition:

1. Only one responsible source exists and no other supplies or services will satisfy agency requirements
2. Unusual and compelling urgency
3. Industrial mobilization, engineering, developmental, or research capability
4. International agreement
5. Authorized or required by statute
6. National security
7. Public interest

When an agency uses one of these exceptions, it must prepare a written Justification and Approval (J&A) signed by an official with appropriate authority. J&As are public documents and are a common source of intelligence for competitors who want to understand why they were locked out of an award.

Full and open competition contrasts with small business set-asides, which restrict competition to specific categories of businesses. Set-asides are not exceptions to competition, they are a form of limited competition authorized by the Small Business Act.

Why Full and Open Competition matters for government contractors

Full and open competition creates the most level playing field in federal contracting. For established contractors, it means facing broader competition including large businesses and new entrants. For new market entrants, it provides access to opportunities that set-asides might exclude them from. Understanding when an agency is expected to use full and open competition versus a set-aside helps contractors decide where to invest capture resources. An agency with a strong small business program history may reserve most procurements, making full-and-open procurements relatively rare for that agency.

Example

The State Department issues an RFP for diplomatic security consulting services with full and open competition. Any responsible company, large or small, regardless of socioeconomic classification, may submit a proposal. A large defense contractor, a mid-tier consulting firm, and two small businesses all compete. The evaluation uses best value tradeoff criteria, and the mid-tier firm wins on the strength of its past performance and technical approach despite not having the lowest price.

Frequently Asked Questions

Can a full and open competition solicitation still have mandatory qualifications?

Yes. Full and open competition does not mean anyone can win, it means anyone can submit. Solicitations may still require specific certifications, clearances, or minimum experience levels. Companies that cannot meet minimum requirements will be found non-responsible and eliminated from consideration.

What is "full and open competition after exclusion of sources"?

This is a FAR Part 6 category allowing agencies to set aside a portion of a procurement for small businesses while competing the rest openly. The set-aside portion uses competition limited to small businesses; the remainder uses full and open procedures.

How do I know if a solicitation is full and open?

SAM.gov postings include a "set-aside" field. If no set-aside is listed, the procurement is generally full and open. The solicitation itself will also state the competitive basis in Section A or the cover page.

Can a contractor protest a lack of full and open competition?

Yes. If an agency restricts competition improperly, through overly restrictive specifications, an unjustified sole-source award, or procedural errors, a contractor can file a bid protest with the GAO or Court of Federal Claims challenging the restriction.