Nonprofits cannot register in SAM without an EIN, as it serves as a mandatory prerequisite for the process. Organizations must first obtain an EIN from the IRS before creating a SAM.gov account. No alternatives exist for this requirement, even for international nonprofits. The registration process includes gathering organizational documents, applying for an EIN, and completing all required SAM sections. Understanding these essential steps guarantees successful navigation through federal registration requirements.
Navigating EIN Requirements for Nonprofit SAM Registration

When a nonprofit organization seeks to register in the System for Award Management (SAM), an Employer Identification Number (EIN) serves as an essential prerequisite. This unique identifier, issued by the IRS, validates the nonprofit’s identity and establishes tax compliance standards necessary for registration. Federal grant opportunities become accessible once registration is properly completed.
The EIN application process typically involves an online submission through the IRS website, with processing times averaging 1-2 weeks. Nonprofit compliance requires accurate documentation of this tax identification number throughout the SAM registration process. Organizations must guarantee their taxpayer name matches exactly what appears on their most recent tax return. Registration approval can take significantly longer, up to seven weeks, for organizations without a TIN during the SAM process.
While SAM registration itself is free, nonprofits cannot complete this process without first securing an EIN. This number remains a fundamental component for grant eligibility and proper entity verification in federal systems.
Alternative Identification Options for Nonprofits in the SAM System

The landscape of nonprofit identification within the SAM system presents significant challenges for organizations without an EIN. Currently, there are no viable alternatives to the Employer Identification Number for completing SAM registration, creating substantial identification challenges for certain organizations.
The Unique Entity ID (UEI), obtained through SAM.gov, has become a standardized identifier, but it supplements rather than replaces the EIN requirement. International nonprofits face additional hurdles, often needing to provide extensive documentation to verify their organizational identity. Incomplete documentation can lead to significant delays in the registration approval process. Organizations must maintain an active registration status in SAM.gov to continue receiving federal financial assistance or participating in government transactions. Registration must be renewed annually to avoid expiration and potential loss of federal funding opportunities.
While the UEI standardizes identification in SAM.gov, nonprofits still face the unavoidable EIN requirement, with international organizations bearing an even heavier documentation burden.
While registration alternatives remain limited, future developments may emerge through government agency collaboration and increasing digitalization of systems.
Organizations seeking federal grants, contracts, or program participation must address these requirements, as SAM registration remains essential for accessing these opportunities.
Step-by-Step Registration Process Without an Established EIN

Maneuvering the SAM registration process requires nonprofits to secure an Employer Identification Number (EIN) as a fundamental prerequisite, despite the article title suggesting otherwise.
In reality, nonprofits face significant registration challenges when attempting to bypass this requirement, as SAM.gov explicitly demands an EIN for verification purposes. Federal funding opportunities require active SAM profiles to ensure eligibility and compliance with government regulations.
For organizations still forming, the proper sequence involves:
- Gather organizational documents (Articles of Incorporation, bylaws)
- Apply for an EIN through the IRS website or phone
- Use the newly acquired EIN to apply for 501(c)(3) status
- Create a SAM.gov account with the EIN
- Complete all required sections including Core Data
Nonprofit alternatives do not exist within the standard SAM framework—obtaining an EIN remains an essential, unavoidable step before registration can proceed. Organizations may experience limited resources during this process, especially when tackling the complex requirements with minimal staff. The costs associated with establishing a nonprofit can range from $500-$1,000, making professional guidance a valuable investment for successful registration completion.
Frequently Asked Questions
How Long Does the SAM Registration Process Typically Take?
The SAM registration timeline typically spans 2-8 weeks, with recent changes potentially extending this to 10+ weeks.
Nonprofit application delays may occur due to organizational complexity, documentation errors, or high processing volumes.
The actual form completion takes approximately 45 minutes, but the full approval process begins after submitting all required documents, including a notarized letter.
Having an Employer Identification Number can greatly expedite the process, while technical issues or incomplete information may cause further delays.
Can Foreign-Based Nonprofits Register in SAM Without a U.S. Presence?
Yes, foreign nonprofits can register in SAM without a U.S. physical presence.
Foreign nonprofit eligibility for SAM registration requires obtaining a DUNS number and an NCAGE code, which are mandatory prerequisites.
Registration challenges include ensuring exact name and address alignment across all databases and providing translated documentation.
While the process presents hurdles with verification and documentation requirements, the SAM system is designed to accommodate international organizations seeking to work with U.S. government agencies.
What Happens if My SAM Registration Expires During Grant Consideration?
When a SAM registration expires during grant consideration, several consequences follow.
First, grant eligibility is immediately compromised, as federal agencies require active registrations to award funds.
Application delays become inevitable, as reviewers may flag or suspend consideration until active status is verified.
Organizations risk automatic disqualification from current opportunities and payment interruptions for existing grants.
Additionally, the reactivation process can take weeks, potentially causing missed funding cycles and damaging relationships with federal funders.
Are There Expedited Options for Urgent Nonprofit Registration Needs?
Expedited options exist for urgent registration needs, but are limited.
The IRS offers expedited processing for Form 1023 only in compelling circumstances, primarily for disaster relief organizations with immediate critical needs.
No official expedited track exists for SAM registration, though careful preparation can minimize delays.
Organizations can speed up their timeline by using Form 1023-EZ if eligible, but this option is unavailable for expedited review.
How Do Recent IRS Backlog Issues Affect Nonprofit Registration Timelines?
Recent IRS delays have markedly extended nonprofit registration timelines, with traditional Form 1023 applications facing the longest waits.
The introduction of Form 1023-EZ has helped reduce registration impact for smaller organizations, typically processing within 22 days versus months for standard applications.
Organizations requiring the traditional form should anticipate extended processing periods, while those qualifying for the streamlined EZ option can expect faster approval timelines.