SAM profiles require thorough ownership disclosure including immediate and highest-level owners with legal names and CAGE codes. Businesses must provide accurate TIN matching IRS records, physical address verification, CAGE code assignment, and certification documentation. Annual renewal is mandatory 365 days after approval, with updates to UEI, TIN, banking information, and two-factor authentication. Failure to disclose accurately may result in rejected bids and False Claims Act allegations. The following sections detail specific requirements for domestic and international entities.
Ownership and Control Information Requirements
The System for Award Management (SAM) now requires thorough ownership disclosures for all entities seeking to maintain active registration status.
Enhanced SAM compliance now demands comprehensive ownership disclosure to maintain active registration for all federal contractors.
These requirements, implemented under FAR Subpart 4.18, mandate identification of both immediate and highest-level owners in an entity’s ownership structure.
For entities owned by other companies, contractors must provide legal names and CAGE codes for their immediate owners (entities directly owning them) and highest-level owners (top entities in the ownership chain).
This applies to complex ownership structures, including trust ownership arrangements common in family-owned government contractors. Family-owned businesses must properly disclose trust agreements when applicable to their ownership structure. These ownership questions are specifically located in the Core Data section of the SAM registration process.
Proper completion of this section is essential during the registration process to ensure you are fully prepared to participate in government contracting opportunities.
Failure to accurately disclose ownership information may result in registration issues, rejected bids, or even False Claims Act allegations.
Contractors should verify all CAGE codes through the BINCS database to guarantee compliance with these mandatory disclosure requirements.
Entity Registration Details and Compliance
Beyond ownership disclosures, successful SAM registration hinges on precise entity information and compliance details. Organizations must accurately provide their start date, fiscal year end date, and proper entity type classification to guarantee eligibility for federal programs. Without proper registration, businesses cannot legally compete for any federal government contracting opportunities.
| Registration Requirement | Compliance Impact |
|---|---|
| TIN matching with IRS records | Prevents registration rejection |
| Physical/mailing address verification | Establishes operational legitimacy |
| CAGE code assignment | Enables defense contracting |
| Certification status documentation | Validates special designations |
The system cross-checks U.S. government exclusion records during registration to confirm eligibility. Organizations must also disclose their country and state of incorporation to verify jurisdictional compliance. International entities require additional country-specific details. For entities seeking Disadvantaged Business Enterprise status, formal certification documentation must accompany the registration to claim this special designation.
Annual Renewal Requirements and Documentation
Maintaining an active SAM registration requires organizations to complete a thorough renewal process annually, as registrations expire exactly 365 days after approval. To guarantee continuous eligibility for federal contracts and payments, entities should initiate annual update procedures 60-90 days before expiration. SAM.gov sends email notifications to registered contacts as deadlines approach. Setting up calendar reminders is also recommended to avoid registration lapses that could disrupt your government business activities.
During renewal, organizations must validate all documentation, including their UEI, TIN, banking information, CAGE code, and NAICS classifications. Business certifications require revalidation, and foreign ownership disclosures need review. Ensuring an error-free registration is crucial as approximately one-fifth of businesses remain ineligible for federal contracts due to registration errors.
The system now requires two-factor authentication for all profile updates, with electronic notarization necessary for banking changes. Special attention should be given to banking information accuracy to prevent disruptions in direct deposit arrangements.
Following submission, renewal processing typically takes 3-5 business days, with registration status updated publicly within 24 hours of approval.
Frequently Asked Questions
How Long Does Initial SAM Registration Typically Take to Process?
Initial SAM registration typically takes 2-8 weeks for processing, with initial processing time varying based on documentation accuracy. Registration delays of up to 10 weeks can occur during system updates or high-volume periods.
What Happens if My CAGE Code Expires During Registration?
CAGE code renewal occurs automatically with SAM registration renewal. If a CAGE code expires during registration, it may cause registration consequences including potential delays in contracting eligibility until the registration process is completed.
Can Foreign Entities Register Without a U.S. Bank Account?
Yes, foreign entities can register in SAM without a U.S. bank account. The international registration process accommodates foreign entity eligibility by requiring NCAGE and DUNS numbers instead of domestic banking information.
How Do I Correct Information After Submission Without Affecting Status?
Registrants can correct information post-submission by accessing the ‘Edit’ function in their SAM.gov account. Corrections to non-core data generally won’t affect registration status, while core data changes may trigger additional validation processes.
Are SAM Registration Fees Required for Certain Entity Types?
SAM registration is free for all entity types. No registration fees are required by the federal government regardless of whether the entity is a business, nonprofit, or government agency.