Primary sources. Published arithmetic. No courses.
Pattern break · Edition 004
GSA's own numbers for fiscal 2025: $39.4 billion across 82 million transactions on 4.2 million active accounts. Average ticket $480. On 1 October 2025 the micro-purchase ceiling rose from $10,000 to $15,000. Under that ceiling, FAR 13.203(a)(2) says a purchase "may be awarded without soliciting competitive quotations," and FAR 4.1102(a) exempts card micro-purchases from SAM registration outright. No CAGE code. No NAICS argument. No schedule.
The entire visible industry around federal selling — registration help, capability statements, set-aside strategy, GSA Schedule proposals — is advice about contracts. It is not advice about the largest, fastest-moving, least contested pool of federal money, which is settled with a Visa at the moment of purchase by someone who is not a contracting officer. There are 4.2 million of those people and, in fiscal 2025, they made 82 million decisions at an average of $480 each.
There is a toll booth, and it is worth naming precisely, because it is the thing most sellers pay without noticing. GSA's Commercial Platforms Program points cardholders at eight commercial sites. In the only period GAO measured, Amazon Business was 96% of that program's sales — and Amazon took an average of 45% of seller revenue in 2023. The platform did not replace the regulation. It replaced the search. GSA's own page says agencies "can choose the awarded platforms that best suit their mission needs": the program is optional, and so is the 45%.
GSA Administrator Edward C. Forst, announcing the SmartPay 4 industry engagement: "With SmartPay 4 handling tens of billions of dollars in transactions." The release states fiscal 2025 at 82 million agency transactions, 4.2 million active accounts, $39.4 billion in spend and $471 million in refunds returned to agencies — $7.2 billion cumulative since inception. Federal Acquisition Service Commissioner Josh Gruenbaum is quoted alongside him. The refund line matters: agencies are paid a rebate for putting spend on the card, which is why the card keeps winning.
Finalized 27 August 2025, effective 1 October 2025. The micro-purchase threshold goes from $10,000 to $15,000 and the simplified acquisition threshold from $250,000 to $350,000. The authority is 41 U.S.C. 1908, which forces a CPI re-basing of statutory acquisition thresholds every five years. Nobody lobbied for this and nobody announced it as policy; an indexation clause quietly pulled a $5,000-wide band of purchases out of competitive procedures. GSA SmartPay Smart Bulletin 002, revised 5 September 2025, is the operational confirmation, and notes the knock-on: convenience checks are capped at half the threshold, now $7,500.
The list of exceptions to the requirement that a contractor be registered in SAM includes, verbatim: "Purchases under the micro-purchase threshold that use a Governmentwide commercial purchase card as both the purchasing and payment mechanism." The other exceptions on that list are classified contracts, deployed contracting officers, danger-pay posts and declared emergencies. That is the company the micro-purchase keeps — it sits in the carve-out written for war zones and disasters, because the drafters concluded the paperwork was not worth $15,000.
13.201(b): "The Governmentwide commercial purchase card shall be the preferred method to purchase and to pay for micro-purchases." 13.203(a)(2): micro-purchases "may be awarded without soliciting competitive quotations if the contracting officer … considers the price to be reasonable." And 13.203(a)(1): "To the extent practicable, micro-purchases shall be distributed equitably among qualified suppliers." Read that last one as a seller rather than a lawyer. The rule does not ask the buyer to find the best vendor. It asks them to not keep using the same one.
The Commercial Platforms Program, created by Section 846 of the FY2018 NDAA, ran $12.5M in FY2021 and $40.4M in FY2022, at an average order of about $270. Share of those sales: Amazon Business 96%, Fisher Scientific 3%, Overstock Government 1%. Small-business share fell from 21% to 18% across the two years, and GAO found the small-business credit process "resource intensive and not practicable." The program has since expanded to eight platforms — Amazon Business, ePS, Fisher Scientific, Glass Commerce, Grainger, Noble, Pacific Ink, Staples.
Amazon hired Anne Rung — the Obama administration's federal procurement chief — in 2016 to build the government side of the business. Stacy Mitchell of the Institute for Local Self-Reliance puts the mechanism plainly: "Amazon is inserting itself between businesses that sell to government and [their customers] and using that position to skim off a chunk of their revenue." LaJuanna Russell of Business Management Associates describes vendors "still selling through Amazon, who is then selling to the government." The figure attached: Amazon took an average of 45% of sellers' revenue in 2023.
Signed by Daniel I. Gordon, Administrator for Federal Procurement Policy, and Danny Werfel, Controller. It directs agencies to rewrite cardholder training to emphasise small-business consideration and to use the shopping sites' small-business search. The baseline it cites: roughly $6 billion went to small businesses at or below the micro-purchase threshold in FY2010, about 30% of card spend, across 260,000 cards. There are 4.2 million accounts now. The demand-side policy is fifteen years old and still pointing the same direction.
$39.4B ÷ 82M transactions = $480 per transaction, matching the figure GSA publishes on its statistics page. So $5,000/month is 10.4 orders at $480, and a year of it is 125 orders — 0.003% of the 4.2 million accounts placing one order each, or 0.00015% of fiscal 2025 card spend. If the 2011 ratio still holds, the small-business slice of $39.4B is about $11.8B (derived, unverified since FY2010). The $500 covers a domain, a card-accepting checkout and a first production run. SAM registration is free and, below $15,000, not required of you.
Seven rungs. Every one of them is a decision to skip a step the federal-selling industry charges to help you complete.
FAR 4.1102(a) exempts card micro-purchases from registration. Registration is free anyway; what it costs is weeks and the belief that qualification is the gate. It is the gate for contracts. It is not the gate for the $39.4 billion that moves on cards. Register later, when a buyer above the threshold asks you to.
$15,000 ceiling · SAM not required · no CAGE, no NAICSThe ceiling is the headline and the average is the business. Eighty-two million transactions at a $480 mean says the cardholder's habit is small, frequent and unexamined. Build something that sells at three figures and repeats, not a $14,900 package that requires someone to think.
$39.4B ÷ 82M = $480 avg · $5,000 ÷ $480 = 10.4 orders/moBelow the threshold, that is the entire compliance surface on your side: the card is both the purchasing and the payment mechanism, and the FAR says so in the exemption itself. A working Visa/Mastercard checkout and an invoice with your address on it is the whole apparatus. No portal, no bid, no bond.
Amazon Business was 96% of the Commercial Platforms Program and takes an average 45% of seller revenue. GSA says agencies "can choose" their platform — the program is optional for the buyer and therefore optional for you. Use a listing to be found; take the reorder direct, where the margin is.
96% platform share · 45% average revenue take · 0% requiredThere is no contracting officer in a micro-purchase — there is a lab manager, a facilities lead, a training coordinator with a card and a limit. That is a consumer sale with a government address, and it is reached the way consumer sales are reached: be specific, be findable, be already priced.
4.2M active accounts · 82M purchase decisions/yrFAR 13.203(a)(1) instructs buyers to distribute micro-purchases "equitably among qualified suppliers." You do not have to displace an incumbent; you have to exist as an alternative the cardholder can point at when someone asks why they always buy from the same place. Almost no one designs for this clause.
The $5,000 of new headroom came from a five-year indexation under 41 U.S.C. 1908, not from a policy decision — which means the widest part of this window is now, before the volume of $10,000–$15,000 purchases reroutes and someone builds the incumbent position inside it. The next re-basing is five years out.
$10,000 → $15,000 on 1 Oct 2025 · next CPI adjustment ~2030Post-ready. Counts are computed live from the text and flag anything over 280.
🧵 Last year the US federal government spent $39.4 billion on credit cards. 82 million transactions. 4.2 million active accounts. Average ticket: $480. Below $15,000 the regulation requires no competitive quotes — and the seller doesn't have to be registered in SAM.
FAR 4.1102(a) lists the exceptions to SAM registration. One of them, verbatim: "Purchases under the micro-purchase threshold that use a Governmentwide commercial purchase card as both the purchasing and payment mechanism." No CAGE code. No NAICS argument. No schedule.
On 1 Oct 2025 that ceiling went from $10,000 to $15,000. A 50% jump, finalized in the Federal Register on 27 Aug 2025, FAR Case 2024-001. It wasn't policy. It's a CPI re-basing forced every five years by 41 U.S.C. 1908. An indexation clause moved $5,000 of headroom.
Consensus: selling to the government means SAM, NAICS codes, set-asides, a GSA Schedule, 18 months. All of that governs contracts. None of it governs $39.4B of card spend. FAR 13.203(a)(2): micro-purchases "may be awarded without soliciting competitive quotations."
So why do sellers pay anyone? Discoverability. GSA routes cardholders to 8 commercial sites. In the only period GAO measured, Amazon Business was 96% of that program's sales. Amazon took an average 45% of seller revenue in 2023. GSA's own page: agencies "can choose."
The move: put a commercial Visa/Mastercard checkout on your own site and sell direct to the cardholder. Below $15,000 that is your entire compliance surface. There is no contracting officer in a micro-purchase. There's a lab manager with a card and a limit. 4.2 million of them.
$39.4B ÷ 82M transactions = $480 average. $5,000/month = 10.4 orders at $480. 125 orders a year. That's 0.003% of the 4.2M accounts buying once, or 0.00015% of FY2025 card spend. $500 buys a domain, a checkout and a first run. SAM is free and you don't need it.
FAR 13.203(a)(1): "To the extent practicable, micro-purchases shall be distributed equitably among qualified suppliers." You don't have to beat the incumbent. You have to be the second name they can point at. The rule is written to spread the money. Nobody designs for it.