Quick Answer
Federal evaluators can and do count commercial, state, and local government contracts as past performance, not just federal ones. Under FAR 15.305 and FAR 9.104-1, a business with no Contractor Performance Assessment Reporting System (CPARS) record gets evaluated neutrally, not unfavorably, so missing that record won't sink your proposal. What matters is presenting your commercial work the way evaluators expect to see it, often through a Past Performance Questionnaire rather than a CPARS report.
A lot of teams treated 2025 like a warm-up lap. Policies were “final,” but awards didn’t consistently test readiness.
