Can a federal agency buy recruiting on a purchase card?

What the micro-purchase threshold is

The micro-purchase threshold is the dollar limit below which a federal purchase can be made with the fewest formalities. FAR 2.101 sets it at $15,000, up from $10,000 under a rule published on August 27, 2025 that took effect on October 1, 2025.

Below that line, FAR 13.203 allows an award without competing quotes when the buyer considers the price reasonable, and asks that micro-purchases be spread fairly among qualified suppliers where that is practicable.

Under FAR 13.201, the government purchase card is the preferred way to buy and pay for micro-purchases, and only people your agency has authorized and trained may make them.

The same section raises the threshold to $25,000 inside the United States when the agency head determines a purchase supports a contingency operation, disaster response or certain other emergencies. That takes a determination, so do not assume it applies to a hiring program.

The lower limit for some services

The Service Contract Labor Standards are the federal rules that set minimum wages and fringe benefits on contracts whose principal purpose is services delivered through service employees. For services subject to them, FAR 2.101 sets the micro-purchase threshold at $2,500, not $15,000.

Whether a recruiting engagement is covered is your contracting office’s decision, so ask before anyone uses a card. The answer changes which route the purchase takes.

Your agency also sets each card’s own limits. GSA’s SmartPay bulletin on the new threshold says agencies are not required to set card limits at the FAR maximum, so your card’s limit may be lower than $15,000.

Placement fees and the $15,000 line

A placement fee is a one-time fee a recruiting firm earns when you hire someone it introduced, set as a share of the hire’s first-year salary. How much does a government recruiting firm cost? covers the usual rates.

One fee can pass $15,000. For example, a market fee of 20% on a $90,000 salary would be $18,000, which is above the micro-purchase threshold, so a contracting officer would buy it with simplified procedures.

Several hires cannot be split to fit. GSA’s purchase card training says it is never permissible to intentionally divide a purchase into parts just to get under your limits, because all the parts of a defined need are one purchase. FAR 13.003 also bars breaking down a requirement above $350,000 into smaller purchases merely to use simplified procedures or to avoid the rules above the micro-purchase threshold. Price the whole engagement and ask your contracting office how to buy it.

Smaller buys fit easily. Ayla’s software is a monthly plan, and two Qualify seats for a year cost $11,976, under the $15,000 threshold.

Buying above the threshold

The simplified acquisition threshold is the upper limit for simplified procedures, and since October 1, 2025 FAR 2.101 sets it at $350,000.

Between the two thresholds, a contracting officer can buy with simplified procedures, often a purchase order against a written quote. The card can still be how you pay: FAR 13.301 lets it place orders where the underlying contract allows and make payments when the contractor agrees to accept the card.

The same section tells agencies not to limit the card to micro-purchases, and to encourage its use for larger purchases where the contractor agrees. Above $350,000, your contracting officer decides how the work is bought and what the firm must have in place.

What to ask the firm for

A written quote is a firm’s priced offer for a defined piece of work, and it is the first document a cardholder or a contracting officer will want. Ask for these before any work starts:

• A written quote naming the work, the fee and when it is due.
• A W-9, so your finance office can pay the firm.
• Whether the firm accepts the government purchase card.
• What happens if a hire leaves early: a replacement or a refund.
• Who at the firm reports to you, and how often.

Ayla sends a written quote and a W-9 on request, and takes a purchase card under $15,000 or a purchase order against its quote.

What the purchase does not change

A recruiting purchase buys help finding and preparing applicants; it never buys the hiring decision. Your agency still runs the announcement, rates applicants, applies veterans’ preference and selects.

That is also what keeps the buy simple. The firm delivers applicants to your process and your HR team keeps every merit decision, as recruiting for agencies explains, and the pricing page lists what the software costs.