Federal Acquisition Regulation (FAR) requires contractors to register in the System for Award Management (SAM) at both offer submission and contract award stages, not continuously. Per FAR 4.1102(a), all offerors must register unless specifically exempted. Contractors have 30 days post-award to complete registration if necessary. Annual renewal is critical, ideally starting 90 days before expiration. Non-compliance results in contract disqualification and potential protest actions. Proper SAM management guarantees uninterrupted eligibility for federal opportunities.

Key FAR Requirements for SAM Registration Compliance

While traversing federal contracting processes, businesses must understand that System for Award Management (SAM) registration compliance forms the cornerstone of eligibility for government contracts.

SAM registration compliance stands as the essential foundation for businesses seeking eligibility in the federal contracting marketplace.

The Federal Acquisition Regulation (FAR) specifically mandates registration at the time of offer submission and at contract award, not continuously throughout the process.

Contracting officers must perform registration verification using the vendor’s Unique Entity Identifier (UEI) through sam.gov or agency-specific systems.

Companies must be aware that FAR 4.1102(a) requires SAM registration for all offerors unless specifically exempted.

If registration isn’t complete at award, contractors have 30 days post-award or until the first invoice submission to register.

This timeline guarantees contractors remain eligible while maintaining proper documentation for payment processing.

Organizations must maintain accurate financial reporting to avoid penalties and potential disqualification from federal funding opportunities.

Foreign vendors with contracts over $30,000 awarded outside the United States are also required to complete SAM registration to facilitate proper payment processing and compliance.

The interim rule, effective November 12, 2024, eliminates the previous requirement for uninterrupted SAM registration that created harsh consequences for contractors.

Maintaining Active Status: Annual Renewal Process

Securing and maintaining an active SAM registration requires vigilant attention to annual renewal requirements, which federal contractors must fulfill to preserve their eligibility for government contracts.

The renewal timeline dictates that businesses should initiate the process at least 30 days before expiration, though many experts recommend starting 90 days in advance to accommodate potential processing delays.

Registration accuracy is paramount during renewal. Entities must validate all organizational information, ensuring every detail remains current and compliant with federal regulations. System for Award Management status remains valid for exactly one year after approval. Expiration of your SAM registration could result in missed opportunities for federal contracts and grants.

The renewal process typically takes up to 10 business days to complete validation, making timely submission essential. According to requirements, renewal must occur at least every 12 months or sooner if entity information changes.

Contractors should implement systematic approaches to renewal management, including setting calendar reminders, establishing internal review procedures, and potentially engaging specialized assistance for complex registrations to maintain uninterrupted compliance.

Consequences of Non-Compliance and Remediation Steps

Failing to comply with SAM registration requirements carries severe consequences that extend beyond mere administrative penalties for federal contractors.

Companies with lapsed registrations face disqualification from contract awards, even when renewal information was submitted before expiration but not fully validated. The GAO and Court of Federal Claims consistently rule against contractors with non-active SAM status at award time. Federal grant applicants must maintain active registration status to be considered for funding opportunities.

When non-compliance occurs, contractors should immediately update all registration information and contact the contracting officer about remediation steps.

Registration best practices include implementing automated reminders for renewal dates and performing validation checks well before proposal submissions. According to the GAO protest decision, contractors must maintain continuous registration status from proposal submission through award to remain eligible. These practices help contractors avoid the non-compliance penalties that can include lost contracts, competitive protests, and significant financial setbacks.

The recent Interim Rule change eliminates the continuous registration requirement while still mandating registration at submission and award times.

Regular monitoring of registration status is essential for maintaining eligibility for federal awards.

Frequently Asked Questions

Can Foreign Entities Register in SAM for U.S. Federal Contracts?

Yes, foreign entities are eligible to register in SAM for U.S. federal contracts if they have legitimate business reasons.

Registration documentation requirements include obtaining a NATO Commercial and Government Entity (NCAGE) Code and a Unique Entity Identifier (UEI).

Foreign entity eligibility is contingent upon having a compatible legal structure and willingness to comply with U.S. federal laws and regulations.

Entities must provide accurate information across all systems and list knowledgeable points of contact during the registration process.

How Long Does the Initial SAM Registration Process Typically Take?

The initial SAM registration timeline typically spans 6-8 weeks from submission to full approval.

Registration processing time can extend to 10 weeks due to recent system updates. While completing the online application takes approximately 45 minutes, the validation period varies based on entity complexity, documentation accuracy, and current system volume.

After submission, entities receive notification of activation status within 10 business days, but complete registration approval requires successful validation by government officials.

Is SAM Registration Required for Subcontractors on Federal Projects?

Subcontractors on federal projects are generally not required to register in SAM, which simplifies federal compliance processes for smaller businesses.

Prime contractors, however, must verify that their subcontractors are not debarred or suspended from federal contracting. This verification can occur through checking the Excluded Parties List or obtaining certification from subcontractors.

While the subcontractor requirements are less stringent, prime contractors bear the responsibility of ensuring their subcontractors’ eligibility for participation in federal projects.

Can Multiple CAGE Codes Be Associated With One UEI?

Yes, multiple CAGE codes can be associated with one UEI.

Each CAGE code represents a distinct physical location or operational division within a business entity, while the UEI serves as the primary identifier for the entire organization.

This UEI connection allows businesses with multiple facilities or divisions to maintain separate CAGE codes for each location while being recognized as a single entity in the federal procurement system.

Are SAM Registration Fees Legitimate or Potential Scams?

SAM registration is completely free through the official government website.

Registration costs imposed by third parties claiming to expedite the process are potential red flags.

Scam indicators include requests for payment to complete or fast-track registration, communications from non-government websites (not ending in .gov), and promises of guaranteed approval.

While legitimate third-party assistance exists for guiding through the process, any company demanding payment for the registration itself should be viewed with caution.