Most business owners who lost HUB certification in November are waiting. Waiting on the class-action. Waiting on the June hearing. Waiting for the Texas Comptroller to sort it out. They picture government contracting as one thing, and EO-45 shut that thing down.
That's one slice of it.
The bigger slice, the federal one, was never touched.
What EO-45 actually did
The Texas HUB program is a state program. Governor Abbott's executive order pulled your certification from the Texas Comptroller's registry. That's it. That's the reach of it.
Your city can now require more bids before awarding you a contract. The Texas Facilities Commission no longer has you in their set-aside pool. State agencies that hit HUB spending goals using your firm — those relationships changed overnight.
But SAM.gov didn't update. The SBA didn't update. The federal procurement system received no instruction from Austin because Austin has no authority over it.
WOSB. SDVOSB. 8(a). HUBZone. Those certifications are still exactly what they were on November 9th.
What "federal set-aside" actually means
The federal government runs its own certification programs for the same types of businesses the HUB program covered. Separate process, separate portal, separate legal framework. The SBA administers them, not the Texas Comptroller, and the WOSB program alone set aside roughly $31 billion in federal contracts last fiscal year.
Women-owned businesses that held HUB certification likely qualify for WOSB or EDWOSB status at the federal level. Veteran-owned businesses have SDVOSB and VOSB.
Self-certification for SDVOSB ended December 22, 2024. Since that date, you need SBA VetCert to qualify for federal veteran set-asides. If you haven't completed VetCert and were relying on self-certification, you may be locked out of veteran set-asides right now. That gap has nothing to do with EO-45. Check your VetCert status at veterans.certify.sba.gov before you bid anything.
8(a) firms and HUBZone businesses: unaffected. Those programs have their own SBA requirements. The Texas Comptroller cannot reach them.
The hard part isn't waiting for the court to fix it
It's realizing you never needed to wait.
40% of businesses that lost HUB status stopped pursuing government contracts after November. Not because their federal certifications were revoked. Because they assumed "government contracts" was one market and EO-45 shut it down.
Texas ranks in the top three states for federal defense contract spending. The Army, the VA, the Air Force, civilian agencies — they all procure heavily in this state. A lot of that work is set aside for firms with the certifications you still hold. The pool of competing firms is smaller right now than it's been in years, because 40% of the usual crowd decided to sit this out.
The June hearing might restore your HUB status. It won't restore the contracts that closed while you waited.
Where to actually look
Federal solicitations post on SAM.gov. Your registration there is tied to your UEI and it expires annually. If you went quiet on federal BD after November and haven't logged in since, it may have lapsed. Missing that renewal by one day disqualifies you from every federal contract regardless of what certifications you hold. Check it before anything else.
Texas also has a state procurement portal separate from the HUB program: ESBD at txsmartbuy.gov. State agencies post solicitations there that aren't HUB set-asides. You can still compete on those.
And local government was never in the HUB program to begin with. The City of Houston, Harris County, Houston ISD, San Antonio Water System — they all run their own purchasing portals. These contracts are often under $50,000, draw fewer bids, and have nothing to do with the state HUB registry.
Before you bid, know where you stand
I built a free tool called the SAM.gov Autopsy that pulls your federal registration status, your certification standing, your award history, and active opportunities in your NAICS code. Takes 90 seconds. No email required before you see your results.
Worst case, everything's fine and you go in knowing it. Best case, you catch a lapsed registration or a missing VetCert that's been quietly costing you for months.
Common questions
Does EO-45 affect federal certifications like WOSB or SDVOSB?
No. EO-45 only affected the Texas HUB program, which the Texas Comptroller administers. Federal certifications are SBA programs governed by federal law. The Texas Comptroller has no authority over them. Your federal set-aside eligibility is unchanged.
Is my SAM.gov registration affected?
No. SAM.gov is a federal system run by the GSA. EO-45 has no effect on it. That said, SAM.gov registrations expire annually — if you went quiet on federal BD after November, check that your registration is still active before you bid anything.
Do I still need SBA VetCert if I had SDVOSB self-certification?
Yes, and this is separate from EO-45. Self-certification for SDVOSB ended December 22, 2024. Since that date, SBA VetCert is required to qualify for federal veteran set-asides. Check your status at veterans.certify.sba.gov.
What is the difference between Texas HUB and federal set-asides?
Texas HUB is a state program for state contracts. Federal set-asides — WOSB, SDVOSB, 8(a), HUBZone — are SBA programs for federal contracts. Completely separate systems, separate portals, separate legal authority. Losing one has no effect on the other.
See where you actually stand.
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