Key federal regulations governing SAM compliance include FAR 4.1102, requiring registration for contract awards above micro-purchase thresholds, and FAR 52.204-7, mandating active registration at offer submission. DFARS 204.1103 adds defense-specific requirements. Contractors must maintain current SAM profiles with valid UEI numbers and CAGE codes, as registration lapses can trigger payment delays, contract termination, and protest vulnerabilities. The regulatory framework guarantees proper contractor validation throughout the procurement lifecycle.
SAM Registration Requirements Under FAR 52.204-7 and DFARS
When seeking federal contracts, businesses must register in the System for Award Management (SAM), the official government database that serves as a centralized registration system.
FAR 52.204-7 mandates registration for all offers above the micro-purchase threshold, requiring companies to possess a unique entity identifier (UEI).
Contractors seeking federal opportunities must register with SAM and obtain a UEI for all bids exceeding micro-purchase thresholds.
SAM registration facilitates eligibility verification, allowing the government to confirm a contractor’s legal status and compliance with federal regulations.
Government procurement specialists rely on SAM as the primary database to streamline contractor information management and bidding processes.
According to DFARS Subpart 204.11, contract documents must use the exact legal name and physical address listed in the SAM profile.
Companies must maintain current registration information, ensuring accuracy at two critical points: offer submission and contract award.
The latest FAR guidance clarifies that continuous registration between these points is not required, though temporary lapses should be avoided. The recent FAR Council Interim Rule issued on November 12, 2024 specifically addressed this issue to reduce confusion and prevent successful awardees from being disqualified.
Critical Timing for SAM Compliance in Federal Procurement
Precisely when a contractor establishes and maintains System for Award Management (SAM) registration creates significant impacts throughout the federal procurement process. FAR 4.1103 requires verification of SAM registration at offer submission, ensuring real-time compliance before contract award can proceed.
Effective registration strategies include initiating renewal at least 60 days before the annual expiration date, preventing costly lapses that could disqualify offers or delay payments. Regular compliance audits enhance a contractor’s ability to maintain good standing in the procurement system. Business information updates must be verified annually to maintain active registration status. Compliance timelines are particularly stringent when contractors receive awards under exceptions, requiring completion within 30 days post-award or at least three days before submitting the first invoice. Under exceptional circumstances like unusual urgency, contracting officers may authorize temporary waivers for immediate contract actions as outlined in FAR 4.1102.
Contracting officers must verify active registration using the unique entity identifier before finalizing awards, as non-compliance can trigger contract termination, payment suspension, and damaged performance records that affect future opportunities.
Consequences of SAM Registration Lapses for Government Contractors
The failure to maintain active SAM registration creates severe and far-reaching consequences for government contractors. When registration lapses, contractors face immediate contract terminations, payment delays, and disqualification from new awards, as established by GAO and COFC precedents in cases like TLS Joint Venture. The strict interpretation of FAR 52.204-7 requires registration at proposal submission and continuous registration until award.
Registration implications extend beyond administrative concerns to significant operational disruptions. An inactive registration invalidates a contractor’s CAGE code, blocking payment processing and creating financial instability. The recent GAO decision in April 2024 reinforced that pre-expiration renewal attempts do not guarantee continuous active status. Organizations risk losing access to federal grants and other forms of government financial assistance when their SAM registration expires.
Contractor penalties can include complete ineligibility for federal work, reputation damage, and substantial revenue losses.
Both GAO decisions and COFC rulings consistently uphold strict compliance requirements, allowing competitors to file successful protests against contractors with lapsed registrations. Even brief registration gaps or system-related delays provide no protection against these severe compliance consequences.
Frequently Asked Questions
Who Can Access My Sensitive SAM Registration Information?
Access to sensitive information in SAM.gov is strictly controlled through role-based permissions. Only authorized individuals with designated roles within an entity can view sensitive registration details.
Entity Administrators have the highest level of access control and can manage user roles and entity data. These administrators can assign or remove roles as needed, but cannot do so across federal and non-federal entities.
SAM also implements security measures to protect this information from unauthorized access.
Can Subcontractors Rely on Prime Contractors’ SAM Registration?
Subcontractors cannot rely on prime contractors’ SAM registration for their own compliance needs.
While subcontractor reliance on primes may seem convenient, each entity must maintain separate registrations if they wish to engage directly with federal contracts.
Prime contractor obligations include verifying subcontractors aren’t excluded parties, but this doesn’t eliminate the benefits of independent registration.
Subcontractors who register separately gain visibility to potential prime partners, access to opportunity notifications, and establish their own government contracting presence.
How Do SAM Exemptions Apply to Emergency Acquisitions?
Federal regulations provide specific SAM exemptions for emergency acquisitions.
Contractors can be exempt from SAM registration when awarded contracts without full and open competition due to unusual and compelling urgency.
Additionally, exemptions apply when contracting officers are deployed in military operations or located outside the U.S. in designated areas.
While contractors involved in emergency operations may initially proceed without SAM registration, they are generally encouraged to register when circumstances permit.
Are Foreign Contractors Subject to Different SAM Registration Requirements?
Yes, foreign contractors face different SAM registration requirements.
They must obtain a DUNS number for each physical location and an NCAGE code for each DUNS number before completing the SAM registration process.
Their business information must match exactly across all systems, including SAM, D&B, and NCAGE.
While U.S. contractors need a TIN, foreign entities without U.S. tax obligations may register without one, though they must still comply with applicable U.S. federal regulations.
Can SAM Registration Be Transferred During Company Mergers?
Yes, SAM registration can be transferred during company mergers.
This process, which addresses merger implications, requires the requesting entities to initiate the transfer through SAM administration channels. Both companies must provide accurate information and documentation, such as merger agreements.
SAM administrators verify this information before approval. Registration continuity depends on the new entity meeting all eligibility requirements.
After transfer approval, both entities must update their SAM records with new business information to maintain compliance.