Buying software with a government purchase card
Yes, a federal buyer can usually pay for commercial software with the government purchase card when the buy is a micro-purchase, which today means $15,000 or less. This guide from Tualatin Federal Solutions explains the rule, the limits that still apply to card buys, what changes above $15,000, and what to ask a reseller for.
The short answer
- The micro-purchase threshold is $15,000 (FAR 2.101).
- For micro-purchases, the purchase card is "the preferred method to purchase and to pay" (FAR 13.201(b)).
- A seller does not need a SAM.gov registration when the card is both how you buy and how you pay, under the threshold (FAR 4.1102(a)(1)).
- You may not split a larger order into card-sized pieces (FAR 13.003(c)(2)).
The threshold is $15,000
FAR 2.101 defines it: "Micro-purchase threshold means $15,000, except it means-" followed by a list of exceptions. The figure rose from $10,000 to $15,000 effective October 1, 2025, in Federal Acquisition Circular 2025-06, which also raised the simplified acquisition threshold from $250,000 to $350,000.
Some buys have higher thresholds. Under FAR 13.201(g), purchases the agency head ties to a contingency operation, attack recovery, international disaster assistance or an emergency or major disaster can go to $25,000 inside the United States and $40,000 outside it, if they have "a clear and direct relationship" to that purpose.
Your own card program may also set a lower limit for your card; NASA SEWP's purchase card page describes the micro-purchase limit as "agency dependent."
What the FAR says about the card
FAR 13.201(b) is the core line: "The Governmentwide commercial purchase card shall be the preferred method to purchase and to pay for micro-purchases." Three more parts of the same section shape a software buy:
- Method. Purchases at or below the threshold "may be conducted using any of the methods described in subpart 13.3, provided the purchaser is authorized and trained, pursuant to agency procedures, to use those methods" (FAR 13.201(c)).
- Paperwork. "Micro-purchases do not require provisions or clauses, except as provided at 13.202 and 32.1110" (FAR 13.201(d)).
- Beyond micro-purchases. FAR 13.003(e) tells agencies to use the purchase card "to the maximum extent practicable in conducting simplified acquisitions," so it can pay for larger buys too, under the rules for purchases above the threshold.
Rules that still apply to a card buy
A card buy is simple, not rule-free. These limits still apply:
- Required sources. "The requirements in part 8 apply to purchases at or below the micro-purchase threshold" (FAR 13.201(e)). Part 8 covers required sources of supply.
- Kaspersky. "Do not purchase any hardware, software, or services developed or provided by Kaspersky Lab" (FAR 13.201(i)).
- Covered telecommunications. Agencies may not buy "any equipment, system, or service that uses covered telecommunications equipment or services as a substantial or essential component of any system," unless an exception applies or a waiver is granted (FAR 13.201(j), pointing to subpart 4.21).
- No splitting. FAR 13.003(c)(2) says "Do not break down requirements aggregating more than ... the micro-purchase threshold into several purchases that are less than the applicable threshold merely to" use simplified procedures or "Avoid any requirement that applies to purchases exceeding the micro-purchase threshold."
If your office needs 40 seats of a product at $500 each, that is a $20,000 requirement, not two $10,000 card buys.
Does the seller need to be registered in SAM.gov?
Usually yes, with one exception that fits card buys exactly. FAR 4.1102(a) says "Offerors and quoters are required to be registered in SAM at the time an offer or quotation is submitted," except for "(1) Purchases under the micro-purchase threshold that use a Governmentwide commercial purchase card as both the purchasing and payment mechanism, as opposed to using the purchase card for payment only."
The last clause matters: if you issue a purchase order and pay it by card, the card is only the payment method, and the seller needs an active registration.
What changes above $15,000
Once a software buy is over the micro-purchase threshold, three things change.
- Small business set-asides. The FAR text on acquisition.gov says buys above the micro-purchase threshold and at or below the simplified acquisition threshold "shall be set aside for small business concerns" (FAR 13.003(b)(1)). The FAR is being rewritten and agencies apply parts of it through deviations, so your contracting office will tell you which version applies.
- The nonmanufacturer rule steps aside, on small business set-asides. SBA's rule says the nonmanufacturer rule and the limits on subcontracting "do not apply to small business set-aside acquisitions with an estimated value between the micro-purchase threshold and the simplified acquisition threshold" (13 CFR 121.406(c)). A small reseller can supply a large publisher's software on those buys with no waiver.
- Registration and competition. The seller needs an active SAM.gov registration, and on multiple award contracts such as NASA SEWP, each order over $15,000 needs "fair opportunity to be considered" (FAR 16.505(b)(1), as SEWP notes).
Veteran set-asides are different again; see what a veteran-owned reseller can supply on a set-aside.
Card buys through NASA SEWP
If your office prefers to stay on a contract vehicle, SEWP supports card buys too: "Credit card purchases under the micro-purchase limit (agency dependent) may be performed by contacting SEWP Contract Holders directly to request a quote." We do not hold a SEWP contract; our contract vehicles page shows our current status.
How common are card-sized software buys?
In fiscal year 2026, 19.3% of federal awards for IT products and software were $15,000 or less (13.1%, or 725 awards, for veteran-owned firms), by USAspending data read on October 24, 2026.
What to ask a reseller for on a card buy
- A written quote with the manufacturer part number, quantity and term dates for each line
- A total at or under your own card limit
- The manufacturer's Accessibility Conformance Report, if your office reviews accessibility (see Section 508 and VPAT help)
- Confirmation that the product is not from Kaspersky Lab and does not rely on covered telecommunications equipment
- A delivery date and the delivery format (license keys, portal access or a shipped box)
- A receipt that matches the charge on your statement
How we handle card orders
Choose "purchase card" as the payment method on our quote form, and the written quote will say how payment works for that order. See how to buy from us for other ways to order.
Questions buyers ask
Can we split a $20,000 software order into two card purchases?
No. FAR 13.003(c)(2) says not to break down requirements that add up to more than the micro-purchase threshold into smaller purchases merely to stay under it or to avoid requirements that apply above it. A $20,000 need is a $20,000 buy. Above $15,000 the buy follows simplified acquisition rules, which under the current FAR text generally means a small business set-aside and a registered seller.
Does the vendor need to be registered in SAM.gov for a card purchase?
Not always. FAR 4.1102(a)(1) excuses SAM.gov registration for purchases under the micro-purchase threshold that use the purchase card "as both the purchasing and payment mechanism." If the card only pays an order placed some other way, such as a purchase order, the seller needs an active registration. Your agency's own card rules may still prefer registered vendors.
Is the micro-purchase threshold $10,000 or $15,000 in 2026?
$15,000. Federal Acquisition Circular 2025-06 raised it from $10,000, effective October 1, 2025, and FAR 2.101 now reads "Micro-purchase threshold means $15,000." Some contingency and emergency purchases have higher thresholds ($25,000 inside the United States, $40,000 outside), and your own card may carry a lower single-purchase limit set by your agency.
Sources
- FAR 2.101, definitions of the thresholds: acquisition.gov/far/2.101
- FAR 13.201, micro-purchases and the purchase card: acquisition.gov/far/13.201
- FAR 13.003, simplified acquisition policy, set-asides and splitting: acquisition.gov/far/13.003
- FAR 4.1102, SAM.gov registration and its exceptions: acquisition.gov/far/4.1102
- 13 CFR 121.406, the nonmanufacturer rule: ecfr.gov, 13 CFR 121.406
- NASA SEWP VI credit card micro-purchasing: sewp.nasa.gov
- The FAR overhaul and agency deviations: acquisition.gov/far-overhaul
Ready to buy? Request a purchase card quote, or browse more guides for software buyers.