Maintaining SAM compliance requires vigilant attention to several key requirements. Contractors must secure a valid UEI, maintain accurate registration data, and monitor critical system maintenance schedules that could impact submissions. Beginning March 2025, subaward reporting will shift from FSRS.gov to SAM.gov with new timelines and thresholds. The November 2024 interim rule eliminates continuous registration requirements, but compliance notifications should still be closely tracked. Proper preparation and training guarantee uninterrupted eligibility for federal opportunities.
Critical SAM Registration Components for Federal Contractors
Every federal contractor must navigate several essential components when registering in the System for Award Management (SAM). The foundation of registration is obtaining a Unique Entity ID (UEI), which replaced the DUNS number in April 2022. This identifier is critical for proposal eligibility and consistent tracking across federal systems. This comprehensive registration process requires meticulous attention to detail to avoid common pitfalls that could delay government contracting opportunities.
Contractors should understand the registration importance at key phases: active SAM registration must be in place at both proposal submission and contract award times. Recent rule changes have clarified that continuous registration throughout the evaluation process is no longer required, reducing administrative burden. The new interim rule, effective November 12, 2024, specifically eliminates the requirement for uninterrupted SAM registration between offer submission and award. The FAR Council implemented this change to alleviate severe ramifications for contractors whose registration inadvertently lapses during the pre-award process.
SAM.gov serves as the primary registration portal where entities must regularly update their information. This platform enables businesses, non-profits, and government agencies to access federal contracting opportunities while maintaining compliance with Federal Acquisition Regulation guidelines.
Navigating System Maintenance and Service Alerts
Why do contractors frequently encounter unexpected obstacles when managing their SAM registrations? Often, these challenges stem from inadequate preparation for system maintenance periods and missed compliance notifications.
Contractors must monitor SAM for scheduled system downtime, which can impact their ability to update registrations or submit time-sensitive proposals. During these maintenance windows, contractors should prepare documentation and review requirements offline so they can quickly complete tasks when the system becomes operational again. Small businesses that maintain proper SAM registration gain access to federal contracting opportunities that can substantially increase their revenue potential.
Additionally, SAM issues important compliance notifications regarding annual renewal requirements, regulatory changes, and registration errors. Contractors should register for these alerts to avoid lapses in their active status. Contractors are responsible for maintaining data accuracy and completeness throughout the entire contract performance period. For contracts exceeding $30,000 awarded to foreign vendors outside the U.S., SAM registration is specifically required unless exceptions for unusual urgency apply.
The government’s recent interim rules clarify that registration is required at proposal submission and award, helping reduce bid protests and unnecessary costs for both parties.
Subaward Reporting Transition and New Compliance Requirements
Federal contractors maneuvering the SAM ecosystem must now adapt to significant changes in subaward reporting protocols. As of March 8, 2025, all subaward reporting has shifted from FSRS.gov to SAM.gov, creating new procedural requirements for compliance-minded organizations.
The subaward eligibility criteria remain consistent, requiring reports for awards equal to or exceeding $30,000 in federal funds. However, reporting timeline adjustments mandate submission by the end of the month following the subaward issuance.
Organizations should note that reporting is now obligation-based rather than disbursement-based. Users must update their SAM.gov roles to include reporting responsibilities and connect existing FSRS accounts to the new system.
During this changeover, organizations should prepare for possible blackout periods and take advantage of available training opportunities to guarantee uninterrupted compliance.
Maintaining a properly registered and updated SAM account is essential for organizations to access the centralized database of federal grant opportunities and ensure continuous eligibility for funding.
Frequently Asked Questions
How Do I Appeal a Rejected Entity Validation?
To appeal a rejected entity validation, organizations should create a SAM incident ticket through the Help portal with a clear subject line.
The appeal process requires attaching annotated evidence that highlights matching fields, including a detailed cover letter, and citing specific regulations.
For validation issues, applicants should cross-check all submissions against official records, verify document format compliance, and provide secondary proof documentation when primary documents are disputed.
Can International Entities Register in SAM.Gov?
Yes, international entities can register in SAM.gov to participate in U.S. government contracts or grants.
The eligibility requirements include obtaining a DUNS number, providing a legal business name, physical address, and securing a UEI through SAM.gov.
While international organizations don’t need a TIN unless they pay U.S. taxes, they must designate foreign ownership status and identify appropriate Points of Contact familiar with the registration purpose.
What’s the Process for Changing My Entity’s Legal Name?
To complete a legal name change in SAM.gov, entities must initiate an update through the “Update Entity” feature in the Existing Entity Registrations panel.
The process requires submitting documentation such as notarized letters or legal documents proving the name change.
Entities should guarantee all documentation shows consistent naming across platforms and verify their registration status is Active, Expired, or WIP before proceeding.
Any existing WIP registrations containing outdated information should be deleted to prevent conflicts.
How Long Does SAM Registration Renewal Typically Take?
SAM registration renewal typically takes 2-4 weeks to complete.
The renewal process should begin at least 60 days before expiration to prevent lapses.
The registration timeline includes several phases: entity validation (3 business days), followed by external agency reviews that may extend processing to 10 business days.
Common delays occur due to data mismatches, incorrect banking details, or outdated NAICS codes.
Monthly status checks using SAM.gov’s Status Tracker tool are recommended during the renewal process.
Are State/Local Government Contractors Required to Register in SAM?
State/local government contractors are not required to register in SAM. Unlike federal contractors, state registration requirements vary by jurisdiction, and SAM registration doesn’t directly apply to state or local procurement processes.
Contractor obligations are determined by each state or municipality’s specific regulations. However, maintaining a SAM registration may provide credibility advantages when pursuing state/local opportunities.
Contractors should verify requirements with the specific government entity they wish to work with rather than assuming SAM registration is necessary.