On April 17, 2026 the Office of Management and Budget (OMB) issued new guidance directing federal agencies to buy more commercial products and services and to take a harder look at procurements that rely on custom or non-commercial solutions. This shift creates an opportunity for small and minority owned businesses that provide proven commercial products and services in IT, telecom, professional services, facilities support, cybersecurity, automation, logistics, and business operations. These firms should position themselves as cost-effective providers that help agencies meet mission needs faster, reduce risk, and avoid unnecessary custom development.

The opportunity also extends to subcontractors that can strengthen prime contractor teams by demonstrating commercial, scalable, and price-competitive capabilities. As “commercial-first” partners, they can become more valuable on new awards, recompetes, and agency efforts to control costs. But they must be visible, prepared, and ready for federal adoption.

Why OMB Issued The Memo

OMB Memorandum M-26-12 implements Executive Order 14271, Ensuring Commercial, Cost-Effective Solutions in Federal Contracts, and reinforces the long-standing federal preference for buying commercially available products and services whenever practicable. Despite long-standing rules favoring commercial buying, a large share of federal contract spending still goes toward non-commercial products and services, including major spending in IT, telecommunications, professional support, and facilities operations. OMB is now directing agencies to take a harder look at those purchases, determine whether commercial options are available, and require senior review before choosing a non-commercial approach.

This direction is consistent with other Administration actions focused on streamlining federal procurement, reducing duplication, consolidating common purchases, and improving the government’s use of proven private-sector solutions. Together, these actions signal a clear policy direction: agencies should buy what the commercial marketplace can already provide and reserve custom solutions for truly justified cases.Top of Form

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Why This Matters to Your Business

This policy shift may expand federal interest in firms that already develop their products and services for private-sector customers before entering the federal market. Those firms may now have a stronger argument for being included in agency market research, acquisition planning, and procurement strategies. This is especially relevant for businesses in sectors OMB identified as areas of significant non-commercial spending, including professional services, IT, telecom, and facilities operations.

The memo also directs agency competition advocates to coordinate with small business directors on ways to lower barriers and encourage new entrants that offer commercial solutions. This gives minority businesses and advocacy organizations a clear basis to request meetings with agency acquisition leaders, OSDBUs, small business offices, and competition advocates.

Leveraging the Opportunities

Small and minority-owned businesses should treat this policy as both a procurement and repositioning opportunity. As agencies revisit acquisition strategies that previously favored custom solutions or narrow requirements, firms that can show proven commercial capability may influence market research, acquisition planning, and future competitions.

The memo also creates a window to track existing non-commercial contracts, upcoming option periods, and recompetes where commercial alternatives may be considered. Because agencies will need stronger evidence to justify non-commercial purchases, minority-owned businesses should make their capabilities easy to find, evaluate, and document. This also supports a broader competition message: commercial buying should expand access beyond large incumbents.

The policy can also create new value for subcontractors that provide commercial products, services, platforms, implementation support, technical expertise, or scalable business solutions. Prime contractors will increasingly need to show agencies that their proposed solutions are commercially grounded and cost-effective. Subcontractors can help primes do that by bringing proven tools, service models, private-sector experience, specialized talent, and innovative delivery methods.

This creates an opportunity for subcontractors to adjust their message. They should not present themselves only as small business participation partners. They should also present themselves as “commercial-first value partner” that can help a prime contractor:

• show that the proposed solution is based on proven commercial practices;
• support agency market research with documented commercial capabilities;
• strengthen the technical approach with commercial tools, platforms, or service models;
• support price reasonableness with commercial pricing benchmarks;
• reduce performance risk through private-sector or multi-customer experience;
• offer adaptable solutions that can be configured to meet agency needs; and
• improve the team’s overall value by combining commercial capability with small and minority business participation.

Subcontractors should seek earlier engagement with prime partners. They should ask to participate in capture planning, solution development, technical discussions, pricing strategy, oral presentations, and market research responses. The earlier they are involved, the more likely they can influence the solution.

The core message is simple: small business subcontractors are not just compliance partners, they can help primes compete and perform in a federal market that is moving toward commercial, cost-effective, and market-tested solutions.

• Position the company as a commercial-first provider.
  Update capability statements, websites, pitch decks, and agency briefing materials to emphasize that the company’s products or services are commercially available, market-tested, scalable, adaptable to government needs, and supported by proven private-sector results.
• Track contracts and opportunities before requirements are finalized.
  Monitor agency spending, forecasts, SAM.gov notices, procurement dashboards, OSDBU events, upcoming option periods, and recompetes—especially non-commercial contracts over $10 million in IT, telecom, professional services, facilities operations, logistics, automation, and business support.
• Engage agencies early and support their market research.
  Request meetings with OSDBUs, small business specialists, program offices, and competition advocates. Provide concise materials agencies can use in acquisition planning, including descriptions, pricing, customer references, use cases, implementation timelines, security credentials, contract vehicles, and past performance.
• Use RFIs, sources sought notices, and draft solicitations strategically.
  Do more than submit a generic capability statement. Explain how the company’s commercial solution can meet the requirement, reduce cost, shorten timelines, limit customization, improve competition, and support price reasonableness.
• Strengthen pricing and value documentation.
  Be ready to explain pricing models, commercial sales history, subscription structures, labor categories, volume discounts, and other benchmarks that help agencies evaluate cost, value, and price reasonableness.
• Build teaming and subcontracting strategies around commercial capability.
  If your company is not positioned to prime, engage potential prime contractors early and show how its commercial tools, services, or delivery models strengthen the team. Provide proposal-ready language explaining how the company reduces customization, speeds deployment, supports pricing, and reflects proven commercial practice.
• Translate commercial success into federal buying language.
  Frame private-sector results in terms federal buyers value, including reliability, scalability, cybersecurity, compliance, cost control, implementation risk, and measurable outcomes. Top of Form

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What You Can Do

The federal government’s renewed focus on commercial buying should be a call to action for you and your business. Do not wait for agencies or prime contractors to define your value. Make clear that your company is not simply a socioeconomic participant in procurement, but a commercial provider already delivering real value in competitive markets.

You should engage agencies, prime contractors, and policymakers now to ensure commercial acquisition expands competition beyond incumbents. A commercial-first strategy must include resilient and diverse small businesses if the government is serious about reducing costs, strengthening supply chains, and bringing more innovation into federal procurement. The businesses that benefit most will be those that move early, document their commercial value clearly, and show how they support both federal small business goals and cost-effective commercial acquisition.