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SAM

Check Your SAM.gov Registration

A known SAM.gov glitch that occurred in spring/summer 2026 affected many vendor registrations. In some cases, NAICS codes, small or other-than-small business status, and representations dropped off or reset to N/A instead of Y/N.(General Services Administration September 16, 2026)

These changes can affect your eligibility and compliance, so take a few minutes to review your registration. (ibid)

How to Check and Fix It:

  • Review Your Registration: Log in to your SAM.gov Workspace, open your entity record, and review the Representations and Certifications section. Confirm that your small business and socioeconomic status representations under 52.219-1 are accurate. (ibid)
  • Check Your NAICS Codes: Make sure your primary and secondary NAICS codes are correct and align with your current size standards. Also, confirm that the NAICS codes associated with your contracts appear in your representations and show Y/N, rather than N/A. (ibid)
  • Update and Re-Certify: If information disappeared or reset because of the glitch or an expired registration, select “Update or renew my entire entity registration” and complete the questionnaire again. (ibid)
  • Contact the Federal Service Desk: If your information vanishes or remains incorrect after a valid renewal, contact the Federal Service Desk (FSD.gov) and report the profile data error. (ibid)

Also Check Your SBA Profile

Compare the size standards and NAICS codes in SAM.gov with your SBA/Dynamic Small Business Search (DSBS) profile. If the information does not match, your small business designation may not display correctly.

Don’t assume your SAM.gov registration is accurate, log in and check it.

Give us a call, and we can walk you through it.

FAR Council Locks In the “Two-Point” SAM Rule

Federal contractors finally have the clarity they’ve needed. After years of inconsistent interpretations and protest risk, the FAR Council has confirmed exactly when an offeror must be active in the System for Award Management (SAM) to qualify for award. (Federal News Network November 6, 2025)

The answer is now simple: You must be active in SAM at two specific moments — when you submit your offer and when the government makes the award. A temporary lapse in between will no longer knock you out of the competition. (ibid)

How We Got Here: A Long Trail of FAR Confusion

The trouble began with a 2018 amendment to FAR 52.204-7. Many interpreted the new language as requiring continuous SAM registration from proposal submission all the way through award, a period that often lasts months or even years. (ibid)

Bid-protest forums like the Government Accountability Office (GAO) and the Court of Federal Claims reinforced that strict reading. Under their approach, even a brief lapse in SAM, caused by something as minor as a banking change or an unintentional delay, could make an otherwise qualified offeror ineligible. (ibid)

Contractors felt the pressure. The rule didn’t improve the government’s ability to select the best solution; it simply turned SAM upkeep into a high-stakes technical trap, especially for small businesses with frequent changes in ownership, banking, or certifications. (ibid)

Recognizing this problem, the FAR Council issued an interim rule in November 2024 clarifying that offerors only needed to be active at submission and at award, not every moment in between. (ibid)

The Final Rule: A Clear, Two-Point Requirement

On August 7, 2025, the FAR Council finalized that approach with no changes. The final rule confirms:

  • Offerors must be active in SAM at two moments only:
    (1) when they submit the offer, and (2) at the time of award.
  • No continuous pre-award monitoring is required.
  • Mid-evaluation lapses are no longer automatically disqualifying as long as registration is active at the two required points.
  • Offerors must still keep SAM reps and certs accurate at all times. (ibid)

This shift materially reduces protest risk and prevents the loss of competitive proposals over minor administrative oversights. It also restores fairness to the process, ensuring that meaningful competition, not website maintenance, drives award decisions. (ibid)

What This Means for Contractors

The rule divides SAM responsibilities into two clear phases:

Pre-Award: Follow the Two-Point Rule

  • Be active at submission.
  • Be active at award.
  • Document both moments.

A simple screenshot or PDF of the SAM “Active” status at each point can quickly resolve any protest issues.(ibid)

Post-Award: Maintain Continuous Registration

Nothing changes here. Contractors must keep SAM active throughout performance and through final payment. A lapse during performance can still cause payment delays and contract complications. (ibid)

Also unchanged: your obligation to keep all reps and certs accurate.
An “active” but inaccurate SAM record creates a different kind of compliance risk. (ibid)

Strengthen Your Internal Processes

The two-point rule lets contractors shift focus from constant monitoring to smart coordination. This is a perfect time to align your teams:

  • Business Development should share projected submission and award timelines.
  • Compliance should flag any upcoming changes that may affect validation.
  • Both teams should ensure timely documentation of SAM’s active status at the two required moments.

When these processes sync, you stay compliant without wasting time chasing SAM status mid-evaluation. (ibid)

The Bottom Line

The new FAR rule delivers long-needed clarity. Instead of punishing contractors for brief, inconsequential lapses, the government now evaluates SAM eligibility at two meaningful points: submission and award. (ibid)

With basic internal controls, contractors of all sizes can easily meet these requirements, reduce protest risk, and keep their attention where it belongs — on winning and performing federal contracts. (ibid)

Do you have questions about lapses or whether you were active at submission and/or award? Give us a call.