Understanding the FAR Council’s New Rule on SAM Registration

On August 7, 2025, the Federal Acquisition Regulation (FAR) Council issued a significant clarification to FAR 52.204-7 concerning the System for Award Management (SAM) registration process. This change addresses an important issue that has previously caused confusion and ineligibility for some government contractors. The updates stipulate that a failure to maintain continuous SAM registration between the proposal submission and contract award phases will not automatically disqualify an offeror, provided they were registered at the time of proposal submission and are registered again at the time of award.

Implications of the Rule Change

The primary intent behind this new rule is to eliminate unnecessary hurdles for contractors due to short lapses in SAM registration. For example, in the case of TLS Joint Venture, LLC, which the Government Accountability Office (GAO) assessed in 2024, the offeror’s registration had lapsed for just one day between the proposal submission and award. Yet, the GAO ruled the company ineligible for the contract. The new FAR rule directly addresses such scenarios, ensuring that minor lapses do not compromise overall eligibility for awards.

Benefits for Contractors

This rule change is largely seen as a reform that promotes common sense within the government contracting community. It acknowledges the realities of the registration process, which can sometimes become a logistical challenge for contractors. Many companies often rely on their internal resources or third-party services to keep their SAM registration active, and unexpected circumstances can occur, leading to temporary lapses. The FAR Council’s amendment provides a safety net, offering contractors peace of mind knowing that they won’t be automatically disqualified for minor oversights.

Caution for Existing Solicitations

However, this reform does not come without its cautions. While the new provisions will apply to solicitations issued after the rule’s effective date, existing solicitations made prior to August 7, 2025, will still require compliance with the previous SAM registration policies. Simply put, if you are competing for contracts under the old rules, you must continue to ensure that your SAM registration is consistently maintained.

This means that contractors should be vigilant in monitoring their SAM status, especially if they are working under solicitations issued before the effective date. Agencies are not obligated to amend existing solicitations to reflect the new rule; this aspect adds another layer of complexity for contractors seeking to navigate the bidding process effectively.

The Importance of Continuous Monitoring

Given the potential ramifications of a lapsed registration, continuous monitoring becomes essential. Contractors should regularly check their SAM status and promptly address any registration issues. Proactive management of your SAM registration can prevent accidental lapses from becoming costly missteps.

This new regulation emphasizes the importance of maintaining an active status in SAM, while also recognizing the challenges that can lead to lapses. It champions a more reasonable approach that values the intent over strictly adhering to procedural faults, aligning rules more closely with the realities contractors face in the field.

Conclusion: A Step Forward for Government Contracting

The FAR Council’s clarification on SAM registration marks a progressive shift in how government contracts are handled and underscores a commitment to making the procurement process more accessible. It reflects a growing understanding of the market challenges contractors face and suggests a pivot towards a more supportive regulatory environment. As contractors navigate this changing landscape, understanding the specifics of these regulations can provide a competitive advantage and foster greater resilience within their operations.

Staying informed about these changes and adapting strategies accordingly will be key for contractors aiming to secure federal contracts successfully.