Federal contractors must immediately report several critical changes in SAM.gov, including ownership modifications, address changes, business size status updates, and legal structure alterations. Additionally, contractors need to report changes to CAGE codes, banking information for payment, and any disbarment proceedings. Prompt reporting prevents registration expiration and potential contract eligibility issues. Failure to update this information may result in delays or rejection of contract awards. The following sections outline specific timeline requirements for each reporting category.
Critical SAM.gov Reporting Changes for Federal Contractors
As federal contractors navigate the evolving landscape of government reporting requirements, significant changes to SAM.gov have transformed how businesses submit mandatory information.
The most notable change is the retirement of FSRS.gov as of March 8th, 2025, with all subaward reporting now conducted exclusively through SAM.gov.
Contractor responsibilities now include ensuring proper workspace setup within SAM.gov to manage reporting roles effectively. Users must confirm their reporting role is assigned for their entity before submission deadlines. Maintaining an active SAM registration is mandatory for all businesses seeking federal contracts and ensures compliance with government requirements.
Federal contractors must adhere to specific reporting deadlines, such as the October 31st requirement for Service Contract Reporting. For FY2024, the DoD has extended this deadline to January 31, 2025 to allow additional time for compliance. After submission, agencies review contractor reports for data consistency and reasonableness, with contractors permitted to make revisions based on feedback until November 30th.
Entity Ownership Disclosure Requirements and Verification Process
Federal contractors must comply with extensive ownership disclosure requirements in SAM.gov registrations, which became mandatory under FAR Subpart 4.18 in 2014. The reporting scope is determined by the entity’s ownership structure, requiring identification of both immediate owners (direct parent) and highest-level owners (ultimate parent).
Federal contractors face stringent SAM.gov ownership disclosure mandates, requiring documentation of both direct and ultimate parent entities.
The CAGE verification process is critical to compliance. Contractors must enter valid CAGE codes for all disclosed owners, which SAM.gov automatically cross-references against the DLA’s BINCS database to verify legal names and addresses. This verification must be completed during initial registration and whenever ownership changes occur. The required questions appear in the Core Data section of the SAM registration interface.
Challenges exist for trust ownership situations, as SAM.gov interfaces lack explicit options for trust registration despite their common role in business ownership structures. Businesses should conduct thorough verification of all entity data to prevent validation errors that could delay registration processing.
Contractors should obtain required CAGE codes before attempting registration updates to avoid processing delays.
Navigating New Registration Procedures and Compliance Mandates
The new SAM.gov registration procedure requires traversing a structured five-step workflow that begins with account creation and culminates in a finalized registration. Entities must submit mandatory documentation, including formation certificates and tax documents, with approval typically occurring within 10 business days after submission. Businesses should ensure they have an Employer Identification Number ready before initiating the process. Following a comprehensive checklist will help streamline the registration process and ensure all requirements are properly fulfilled.
| Registration Workflow Phase | Required Documentation | Compliance Deadlines |
|---|---|---|
| Account Creation | Email verification | Immediate |
| Entity Details Input | Business information | 24 hours to save progress |
| Documentation Submission | Formation certificates, IRS documents | Before submission deadline |
| Unique Entity ID Assignment | N/A | Automatic upon verification |
| Registration Finalization | Bank account details | 10 days before contracting |
After registration, entities must monitor system alerts regarding maintenance windows and conduct regular status checks through the SAM.gov portal to maintain compliance with federal contracting requirements.
Frequently Asked Questions
How Quickly Must Changes to SAM Registration Information Be Reported?
SAM registration information must undergo timely updates as soon as changes occur. Maintaining registration accuracy is essential, as delays can lead to inactive status and affect eligibility for federal contracts and grants.
Are Foreign-Owned Entities Subject to Different SAM Disclosure Requirements?
Foreign-owned entities face additional sam disclosure requirements, including ownership structure reporting, remittance address verification, and foreign headquarters location. These foreign entity disclosures create unique compliance challenges regarding banking information and government relationship reporting.
What Penalties Exist for Non-Compliance With SAM Reporting Requirements?
Non-compliance with SAM reporting requirements can trigger various penalty enforcement mechanisms, including contractual remedies, negative performance evaluations, potential contract suspension or cancellation, and adverse impacts on future award eligibility. These compliance consequences protect government interests.
Can Contractors Request Exemptions From Certain SAM Disclosure Requirements?
Contractors cannot request exemptions from SAM disclosure requirements outside predefined categories. Exemption criteria are strictly limited to those specified in FAR 4.1102(a), with contractor eligibility determined automatically based on contract type or circumstances.
How Do SAM Reporting Requirements Differ for Small Businesses?
Small businesses have distinct reporting thresholds in SAM based on their specific small business qualifications. They represent eligibility for various contracting programs while maintaining the same core registration and update requirements as larger entities.