Using outdated SAM registration information poses significant business risks, including contract disqualification and compliance violations. A recent interim rule (November 2024) removes continuous registration requirements but still mandates active registration at offer submission, award, and throughout performance until final payment. Organizations should implement quarterly data reviews, set expiration reminders, and validate critical information using SAM.gov tools. Proper registration maintenance prevents costly administrative delays, lost opportunities, and potential False Claims Act violations.
New Interim Rule Removes Continuous SAM Registration Requirement
While government contractors have long struggled with maintaining uninterrupted SAM registration, the FAR Council has now provided relief through a significant regulatory change.
The interim rule, published on November 12, 2024, eliminates the requirement for continuous SAM registration between offer submission and award.
This contractor compliance modification addresses a common challenge where even one-day lapses in registration could disqualify otherwise valid bids.
The SAM registration changes now require active registration at two key points: when submitting an offer and at contract award. Contractors must still maintain active registration throughout performance and until final payment. This change directly responds to past bid protests that had resulted in contractor disqualification over minor registration technicalities.
Active SAM registration now required only when submitting offers and at contract award, with continuous registration during performance through final payment.
System for Award Management serves as the government’s central database for vendor information and compliance verification.
The rule takes effect immediately, with public comments for the final version due by January 13, 2025.
This change aims to reduce bid protests, minimize administrative burdens, and increase small business participation in federal contracting.
The interim rule specifically addresses concerns from Court of Federal Claims decisions that previously enforced strict SAM registration requirements throughout the procurement process.
Risks of Relying on Outdated SAM Registration Information
Nearly all government contractors face significant risks when using outdated information for their System for Award Management (SAM) registrations. Outdated business names, addresses, or points of contact create serious compliance challenges during the renewal process, often leading to validation issues that block registration renewal. The FAR 52.204-7 provision requires active registration from the time of proposal submission through contract award. The centralized database system helps contractors maintain accurate, up-to-date information for government procurement opportunities.
The registration consequences can be severe and immediate. Contractors with expired or inaccurate SAM registrations become ineligible for federal contract awards, regardless of how competitive their proposals may be. Recent GAO decisions confirm that even brief registration lapses can disqualify companies from lucrative opportunities. This was clearly demonstrated in the case where GAO sustained a bid protest against a Navy contract because the awardee’s SAM registration lapsed before the contract was awarded.
Financially, the costs extend beyond lost contracts. Companies waste proposal preparation expenses when disqualified due to registration issues, and may face costly legal challenges or protests resulting from non-compliance with SAM requirements.
Best Practices for Maintaining Current SAM Registration Status
Every successful government contractor relies on systematic approaches to maintain accurate SAM registration information. Implementing a robust registration maintenance schedule is essential, with quarterly reviews of core data elements against current business records.
Organizations should establish compliance tracking logs that document when reviews occur and what changes were implemented. Federal funding eligibility depends entirely on maintaining active SAM registration status.
Effective SAM management requires:
- Setting calendar reminders at 60, 30, and 15 days before expiration
- Designating primary and backup Points of Contact (POCs)
- Validating critical information using SAM.gov verification tools
- Promptly updating records within 30 days of business changes
Companies should also cross-reference their Taxpayer Identification Number, CAGE code, and entity information annually to guarantee consistency across all government systems. Outdated SAM information can potentially lead to False Claims Act violations with serious legal consequences.
This proactive approach prevents administrative delays that could impact contract eligibility or payment processing. Contractors should remember that unique entity identifier changes must be reported to the Contracting Officer within the required timeframe to maintain compliance.
Frequently Asked Questions
How Long Does the Initial SAM Registration Process Typically Take?
The initial SAM registration timeline typically spans 7-10 business days after complete submission, though it can extend to 2-8 weeks depending on business complexity.
The application process requires approximately 45 minutes to complete the online form, followed by document verification and processing.
Factors affecting completion time include document readiness, errors in submission, and whether the entity has an established EIN/TIN.
Activation confirmation emails generally arrive within 1-5 days after submission.
Can Foreign Entities Register in SAM for U.S. Federal Contracts?
Yes, foreign entities can register in SAM to bid on U.S. federal contracts.
Foreign eligibility requirements include obtaining an NCAGE code and Unique Entity ID (UEI) before completing registration. These entities must select “Foreign Owned and Located” during the process and provide accurate business information that matches across all systems.
While foreign entities aren’t required to provide a TIN/EIN unless they pay U.S. taxes, they must still comply with all applicable U.S. federal regulations.
What Happens if SAM Experiences Technical Issues During Proposal Submission?
When SAM experiences technical issues during proposal submission, contractors may face significant challenges.
Technical difficulties can lead to proposal delays that might result in missed deadlines. Agencies typically have limited flexibility regarding late submissions, even when caused by system errors.
Contractors should document all technical problems and immediately contact the contracting officer to explain the situation.
Best practice includes submitting proposals well before deadlines to allow time to address any unexpected system problems.
Are Subcontractors Required to Maintain SAM Registration?
Yes, subcontractors are required to maintain SAM registration to participate in federal contracts. This registration compliance requirement guarantees subcontractors remain eligible for federal subcontracting opportunities.
Subcontractors must register using the same process as prime contractors, obtain a Unique Entity ID, and renew their registration annually. Among subcontractor responsibilities is providing accurate business information, including financial statements and applicable NAICS codes.
Failure to maintain active registration may result in ineligibility for new federal subcontract awards.
Can Multiple Divisions of the SAMe Company Have Separate SAM Registrations?
Yes, multiple divisions of the same company can and should have separate SAM registrations.
Federal regulations require individual registrations for each division that intends to bid on federal contracts or receive federal funds.
Each division must obtain its own unique UEI and maintain distinct registration information that accurately reflects its specific legal structure and operations.
This division requirements approach guarantees proper tracking of contract awards and compliance with federal procurement regulations.