Interim FAR rule clarifies SAM preaward registration requirements

An interim rule, effective on publication and issued by the FAR council, makes revisions to clarify System for Award Management (SAM) preaward registration requirements. Effective 12 November 2024, the rule states that contractors must be registered in SAM at the time of offer submission and at contract award but are not required to maintain continuous registration throughout the preaward period.

The clarification follows confusion from the 2018 FAR update, which some courts and contracting officers interpreted as requiring uninterrupted registration. This led to bid protests and disruptions, particularly for small businesses. The clarified rule aims to mitigate litigation risks, reduce unnecessary barriers to entry for contractors, and support government missions by simplifying compliance expectations.

The rule also updates FAR 52.204-7 to align with SAM registration requirements applicable after contract award, directing contractors to maintain registration only during contract performance and through final payment. Comments on the interim rule are open until 13 January 2025.