News•Feb 6, 2026
OHA Reminder: Compliance with SBA Joint Venture Requirements Is Determined at Final Proposal Revisions
The SBA Office of Hearings and Appeals (OHA) clarified that compliance with joint‑venture requirements under 13 C.F.R. § 128.402(c) is judged at the date of a final proposal revision, not the initial offer. In the GSA‑led protest VSBC‑459‑P, OHA ruled that MindVen’s SDVOSB joint venture, which amended its agreement on December 7 2022, was compliant as of its January 4 2024 final revision, leading to a denial of GSA’s protest. The decision underscores that the same timing rule applies to mentor‑protégé, 8(a), WOSB, and HUBZone joint ventures. Contractors must therefore verify JV agreement compliance before submitting any revised proposals.
