The shift from DUNS to UEI numbers in 2022 transformed federal contracting identification systems. DUNS was a 9-digit identifier managed by a third party, while UEI is a 12-character code obtained directly through SAM.gov. EIN remains a separate 9-digit tax identifier issued by the IRS. Contractors must have valid UEI registration at proposal submission and contract award stages, but continuous registration is no longer required. Proper understanding of these identifiers prevents registration delays and contracting obstacles.

Understanding the Three Key Identifiers: DUNS, UEI, and EIN

Identification numbers serve as critical components in the federal contracting landscape, with three distinct identifiers playing pivotal roles for businesses seeking government opportunities. Each identifier serves a specific purpose in the government contracting ecosystem:

The DUNS (Data Universal Numbering System) was a 9-digit identifier issued by Dun & Bradstreet to track business credit histories until its phase-out in 2022. The UEI (Unique Entity Identifier), a 12-character code issued through SAM.gov, has replaced DUNS as the primary identifier for federal contract participation. Accurate entry of UEI information is essential to avoid delays and potential disqualification from government contracts.

Unique identification has evolved from DUNS to UEI, transforming how businesses establish their digital identity in federal contracting.

Meanwhile, the EIN (Employer Identification Number) is a 9-digit tax identifier issued by the IRS for business tax reporting.

These numbers operate independently, with no functional overlap: UEI for government contracts, EIN for tax compliance, and DUNS for historical credit tracking. Many businesses are familiar with DUNS numbers as they have been widely utilized by various institutions including the European Commission and United Nations for business vetting purposes. The UEI must be formally requested through SAM.gov rather than being automatically assigned to businesses.

The 2022 Transition: How DUNS Was Replaced by UEI

Evolution marks the federal contracting landscape as the government changed from DUNS to UEI on April 4, 2022, representing a significant shift in entity identification protocols.

This alteration required SAM.gov to undergo a three-day downtime from April 1-4 while systems were updated to accommodate the new identifier.

Entities with registrations expiring between March 18 and April 18, 2022, received an automatic 60-day extension to ease the alteration burden.

Following the implementation date, organizations could request UEIs directly through SAM.gov without first obtaining a DUNS number, streamlining the registration process.

DUNS numbers are no longer accepted or displayed in the system.

This change fulfilled multiple objectives: ending reliance on a third-party system, reducing costs, and improving entity identification efficiency across federal programs.

A thorough final review of all registration information helps prevent costly errors and registration delays.

Only entities receiving direct payments from FCC must obtain a UEI and complete full registration in SAM.gov to maintain program eligibility.

Registration Requirements and Best Practices for Federal Contractors

Federal contractors seeking to work with the government must navigate a precise set of registration requirements to guarantee eligibility for contracts and payments. The process no longer requires continuous registration, but entities must be registered at proposal submission and contract award stages. The interim rule clarifies that lapses in SAM registration between submission and award will not disqualify an offeror, which alleviates previous harsh consequences faced by contractors. This clarification addresses years of misinterpretations stemming from the 2018 amendment that led to successful bid protests based on registration gaps.

Contractors must register in SAM at least three days before submitting their first invoice or within 30 days of receiving a contract. Accurate documentation of business details, banking information, and NAICS codes is essential for successful registration. Entity Management updates are crucial for maintaining accurate contact information and avoiding missed contract opportunities.

Best practices include registering well in advance of bid submissions, performing regular status checks, and promptly updating any business information changes. Contractors should maintain all supporting documentation for potential audits and utilize government resources to stay informed about compliance requirements.

Frequently Asked Questions

What Happens if My UEI Validation Fails?

UEI validation failure can result in serious business impacts.

When validation fails, an organization’s SAM registration may be suspended, preventing access to federal contracting opportunities. The company may experience payment processing delays, funding disruptions, and potential bid protest challenges.

System lockouts can occur after repeated failures. Organizations should promptly address validation errors by checking data accuracy, contacting SAM support, and considering professional assistance for complex registration issues.

Can I Use My Old DUNS Number for Non-Federal Purposes?

Yes, organizations can continue using their DUNS numbers for non-federal purposes.

While UEI has replaced DUNS for federal contracts and grants, DUNS numbers remain valid and necessary for:

• Commercial credit assessments with banks and lenders
• Supply chain verification with private sector partners
• International transactions with non-U.S. entities
• Financial applications like loans and bond issuances
• Accessing Dun & Bradstreet credit reports and analytics tools

The DUNS number remains independently managed by Dun & Bradstreet for these non-governmental purposes.

How Long Does UEI Assignment Typically Take?

UEI assignment typically occurs immediately during initial SAM registration submission when no issues are present.

However, the standard processing timeline varies:

• 3-10 business days for full registration activation
• 10+ days when external validation checks are required
• Weeks or months for complex cases with discrepancies

Businesses can accelerate this process by pre-validating their TIN with the IRS, using the entity registration lookup tool before submission, and ensuring all documentation is accurate and complete.

Are International Entities Subject to Different UEI Requirements?

International entities follow the same core UEI requirements as U.S. organizations but with additional preliminary steps.

Foreign entities must first obtain an NCAGE code before starting SAM.gov registration, which validates their physical location. They must submit notarized proof of legal existence, such as certificates of incorporation or government-issued licenses.

While the UEI assignment process is identical, international entities use their country-specific tax IDs rather than U.S. EINs during registration.

Can a Single Organization Have Multiple UEIS?

No, a single organization cannot have multiple UEIs for the same legal entity. Each organization receives one UEI tied to its specific legal business name and physical address.

However, different divisions or subsidiaries that operate as separate legal entities with distinct addresses can obtain their own UEIs.

Organizations with multiple locations operating under the same legal structure must use their single assigned UEI for all federal transactions.