SAM.gov enhances federal award transparency beyond FSRS through centralized reporting, improved data accessibility, and standardized compliance verification. The change occurring March 2025 maintains the $30,000 subaward reporting threshold but introduces stricter executive compensation disclosure requirements, including details on perks exceeding $10,000 and ESG factors in compensation decisions. Organizations must register properly in SAM.gov, assign appropriate reporting roles, and prepare for the one-week blackout period during the switchover. Further details below explain critical preparation steps.
SAM vs. FSRS: Key Differences in Reporting Requirements
Since the retirement of FSRS.gov on March 6, 2025, federal subaward reporting has undergone significant changes with the migration to SAM.gov.
The consolidated system now handles all reporting functions previously managed by FSRS, creating a more streamlined process for prime contractors and grant recipients.
Federal award reporting now flows through a single, efficient channel, simplifying compliance for prime recipients.
SAM.gov differs from FSRS by centralizing various federal award reporting functions and integrating directly with USASpending.gov for enhanced transparency.
The subaward criteria remain consistent—awards of $30,000 or more must be reported—but the system offers improved error reduction through digitization.
Reporting deadlines continue to require submission by the end of the month following the subaward, though CARES Act recipients follow quarterly schedules.
This integration allows for better data accessibility, standardization, and compliance verification.
Businesses seeking federal contracts must complete SAM.gov registration as a prerequisite step in the government procurement process.
For those affected by the change, entity administrators in SAM.gov are responsible for assigning new roles to staff members who need to access the subaward reporting capabilities.
Executive Compensation Data: Disclosure Standards Under New SAM Framework
The management of executive compensation disclosure represents another significant aspect of the SAM.gov consolidation.
The updated framework now requires organizations to report detailed information about executive perks exceeding $10,000 in aggregate value, including stock awards, deferred earnings, and life insurance premiums. This requirement applies to the five highest-paid executives across entities receiving federal awards. These disclosure requirements apply to contractors who receive 80% of revenues from Federal contracts and have at least $25,000,000 in annual gross revenues. Compliance with these requirements is essential as active registration in SAM.gov is mandatory for all businesses seeking eligibility for government contracts.
The framework also mandates increased transparency regarding clawback policies, requiring expanded descriptions of both Dodd-Frank-mandated and voluntary provisions in proxy statements. Companies must explicitly indicate whether they have checked the required clawback-related boxes on regulatory forms like 10-K, 20-F, and 40-F when recovery is triggered.
Organizations must now provide explicit reporting of earnings tied to short and long-term performance metrics under non-equity incentive plans.
Additionally, the new standards include mandatory explanation of environmental, social, and governance factors integrated into compensation criteria.
Navigating the March 2025 Transition: Preparing for Changes in FFATA Reporting
When federal contractors approach the March 2025 shift deadline, they must prepare for significant reporting changes as FSRS.gov officially retires and all Federal Funding Accountability and Transparency Act (FFATA) reporting migrates to SAM.gov.
Organizations implementing conversion strategies should note the one-week blackout period in early March, with March 8, 2025, confirmed as the technical cutoff date. Successful transition requires proper registration in SAM.gov, which is mandatory for all entities seeking federal funding opportunities.
Effective compliance challenges management requires organizations to maintain backup documentation for awards processed during the blackout period. Organizations should also remain aware that executive compensation reporting requirements continue to be mandatory despite the transition to the new system.
The new system preserves the 30-day reporting window while introducing automated validation checks to reduce errors.
Users must establish new SAM.gov team permissions to maintain reporting continuity, as UEI-based access will consolidate subaward reporting under single accounts, streamlining multi-entity management for organizations with multiple identifiers.
Frequently Asked Questions
Are International Organizations Required to Register in SAM?
International organizations can register in SAM but are only required to do so when seeking federal contracts or grants. International registration involves additional steps including obtaining NCAGE codes to meet SAM compliance requirements.
How Do Subrecipients Verify Their Data Was Properly Reported?
Subrecipients verify data reporting accuracy by accessing FSRS.gov to review submitted information, checking SAM.gov for registration status, reviewing pass-through entity records, and confirming data verification through audit documentation or compliance reports.
What Are Penalties for Non-Compliance With FFATA Reporting Requirements?
FFATA non-compliance consequences include grant suspension, funding clawbacks, and corrective action requirements. While no fixed penalty guidelines exist, federal agencies determine severity case-by-case, with reporting consequences potentially affecting future funding eligibility.
Can Multiple Users Share a Single SAM Account?
No, multiple users should not share a single SAM account. SAM.gov prohibits credential sharing for security reasons and proper account management. Each user should obtain individual credentials with appropriate role-based access permissions.
Will Historical FSRS Data Be Accessible After the Transition?
Historical FSRS data will remain accessible after the shift to SAM.gov. The full data migration guarantees continuity, with all subaward reporting information transferred to SAM.gov’s systems for continued fsrs accessibility following the March 2025 retirement.