SAM profiles require complete ownership disclosure, including detailed information about all entities in the ownership chain with associated CAGE codes. Businesses must accurately complete all representations and certifications, maintain documentation for five years, and keep NAICS codes aligned with actual business activities. Ownership information about trusts must be disclosed even when not listed in dropdown menus. False or incomplete information risks contract disqualification and potential False Claims Act violations. Proper maintenance guarantees continued eligibility for federal opportunities.
Revealing Ownership Structure: What Must Be Disclosed
Federal contractors must disclose detailed ownership information in their System for Award Management (SAM) profiles to maintain compliance with federal regulations. This includes providing CAGE codes for all entities in the ownership chain, from immediate to highest-level owners, with verification through SAM.gov’s CAGE Ownership Details page. All ownership disclosures are part of the new requirements implemented effective November 1, 2014, as part of Federal Acquisition Regulation Subpart 4.18.
The disclosure requirements apply broadly to various entity types, including trusts, even when SAM.gov dropdowns don’t explicitly list them as options. Contractors must conduct thorough ownership verification using DLA’s BINCS search tool to identify owner CAGE codes when unknown. Family trusts used in family-owned businesses require special attention for accurate registration and disclosure.
Chain disclosures must be complete regardless of whether entities are publicly or privately held, with no exemptions for privately owned companies. Incomplete or inaccurate ownership information risks False Claims Act violations, bid rejections, and adverse protest outcomes.
Navigating Representation and Certification Requirements
While seeking federal contracts, companies must accurately complete numerous representations and certifications within their SAM profiles to demonstrate compliance with government requirements.
These include documenting SBA certifications (8(a), HUBZone), confirming compliance with federal labor laws, and proper NAICS code alignment with size standards.
Accurate SBA certification documentation and NAICS alignment remain essential steps for contractors pursuing federal opportunities.
Annual certification updates form a critical component of SAM maintenance, with immediate notification required for ownership changes affecting eligibility status. For small businesses, maintaining an accurate representation is crucial as it helps confirm eligibility under SBA size standards for contract opportunities.
Contractors face compliance challenges when managing specific requirements like FAR 52.204-24 for telecommunications representations and DFARS 252.204-7012 for safeguarding defense information.
Companies must maintain thorough documentation supporting all certifications for at least five years, while preparing for potential System for Award Management Compliance Reviews (SAM SCR) to validate the accuracy of their representations. Regular updates to the SAM profile are necessary to ensure active status and prevent registration expiration that could disqualify businesses from government opportunities.
Critical NAICS Code Selection and Maintenance
Every government contractor must understand the central role of North American Industry Classification System (NAICS) codes in their SAM profile management strategy. Selecting NAICS codes requires strategic consideration, as these classifications directly impact contract opportunities and visibility to federal agencies.
The NAICS code importance cannot be overstated when building an effective SAM profile:
- Primary codes should accurately reflect core business activities
- Limit selections to 3-5 codes to demonstrate clear business focus
- Review and update codes regularly as business operations evolve
- Guarantee consistency between SAM registrations and other business documents
- Verify compliance with federal classification standards through regular audits
Contractors should utilize available resources like NAICS lookup tools and SBA guidance when selecting NAICS codes to maintain accurate representation of their capabilities.
Frequently Asked Questions
How Do I Update My SAM Profile After a Merger?
After a merger, organizations must update their SAM profile to maintain profile accuracy and address merger impact. They should:
- Log into SAM.gov using current credentials
- Navigate to the Entity Registration section
- Select “Update Entity”
- Modify business name, entity structure, and contact information
- Update DUNS number or UEI if necessary
- Submit changes for review
Organizations should expect approval within 5-7 business days and guarantee all documentation reflects current post-merger status.
What Happens if My SAM Registration Expires During Contract Performance?
When SAM registration expires during active contract performance, it creates significant contract continuity issues. The government may:
- Freeze progress payments immediately
- Prohibit authorization of new work
- Initiate contract termination procedures
Registration implications extend beyond payment disruptions to potential breach-of-contract claims and subcontractor relationship damage.
Contractors must reinstate registration promptly, which requires validation through multi-agency clearance and updated entity information submission, often with unavoidable processing delays.
Can Foreign Entities Register in SAM Without a U.S. Bank Account?
Foreign entities can register in SAM without a U.S. bank account. While foreign registration challenges exist, international banking requirements do not mandate a U.S. financial institution.
SAM guidelines specifically state that foreign banking information is not accepted, but U.S. bank details remain optional for international registrants.
Entities must still provide remittance information and comply with other requirements, including obtaining a UEI and NCAGE code for successful registration and participation in U.S. federal opportunities.
How Long Are SAM Disclosures Publicly Viewable After Registration Expiration?
SAM disclosures remain publicly viewable for approximately six months after registration expiration.
During this period, the entity’s registration visibility continues in a limited capacity, but with an “expired” status clearly indicated.
After this disclosure duration, the information becomes archived and is no longer readily accessible to the public.
However, federal officials may still access historical registration data through internal systems for audit and compliance purposes.
Are Cybersecurity Certification Requirements Different for Classified Contract Eligibility?
Cybersecurity standards for classified contracts differ greatly from standard requirements.
The Department of Defense mandates higher CMMC levels (typically Level 3 or above) for contractors handling classified information, compared to lower levels for unclassified work.
Unlike basic SAM registration, classified contracts require third-party CMMC audits rather than self-certification.
Companies must demonstrate advanced security controls, undergo rigorous assessments, and maintain strict compliance to qualify for classified contract eligibility.