UEI registration for SAM requires obtaining a 12-character alphanumeric identifier through SAM.gov. Organizations must verify their legal name and physical address, designate an entity administrator, and maintain active registration status. Primary recipients need complete SAM registration, while first-tier subrecipients only require a UEI. The process typically takes up to one month, with preparation of required documentation improving efficiency. Further details reveal important exemptions and compliance requirements for federal contractors and grantees.
Understanding the UEI Registration Process
Before an entity can participate in federal contracts or grants, they must complete the UEI registration process through SAM.gov. This process begins with designating an entity administrator who will manage the registration using Login.gov credentials, including email, password, and two-factor authentication.
The validation process consists of several key steps. First, the entity administrator must confirm the exact legal name and physical address in the SAM.gov system. The system then cross-checks this information against public and private databases to verify consistency. The UEI is a 12-character alphanumeric identifier required for all entities receiving federal funds since April 2022. Maintaining an active registration status is required for all EXIM transactions and policy renewals.
Entity validation requires exact legal name and address verification through SAM.gov’s cross-referencing with multiple databases.
International entities must also obtain an NCAGE code. This transition from DUNS to UEI has simplified the process for businesses seeking to engage in government contracting opportunities.
Upon successful validation, SAM.gov automatically generates a Unique Entity ID (UEI), which appears as “ID Assigned” in the workspace. This identifier replaces the previously used DUNS number. The UEI remains unchanged unless the entity undergoes legal restructuring, providing a stable identifier for federal interactions.
Timeline and Planning for SAM Registration
Since federal registration processes involve multiple steps and potential verification delays, organizations must develop a realistic timeline when planning their SAM registration.
While the initial registration can begin in just 15 minutes, the complete process may extend up to one month depending on documentation accuracy.
Organizations should prepare all required information before starting, including legal names, addresses, and incorporation dates. This preparation greatly improves registration efficiency and reduces common errors that cause delays.
Once the registration becomes active, NSF requires an additional two business days to process the information.
Pay close attention to communications from the CAGE system, which may request additional verification within a strict three-day response window. Accurate TIN validation with the IRS is critical as mismatches between organization name and taxpayer information will cause significant delays.
Creating a login.gov account is an essential step in the SAM registration process for entities seeking to do business with the federal government.
New organizations cannot register with NSF until their SAM information is fully processed, making advance planning essential. Regular monitoring of registration status helps identify and address potential issues before they impact critical deadlines.
Subrecipient Compliance With Federal UEI Mandates
While primary recipients must complete full SAM registration, federal guidelines establish different requirements for subrecipients receiving federal funding. Under 2 CFR Part 25, first-tier subrecipients must obtain a Unique Entity Identifier (UEI), but are not required to complete the extensive SAM registration process that primary recipients undergo.
Federal regulations draw a clear distinction: primary recipients need full SAM registration while subrecipients only require a UEI.
This distinction creates specific subrecipient obligations while reducing compliance challenges. Subrecipients can use an abbreviated registration process through SAM.gov to obtain their UEI, which validates their legal business name and address. Foreign organizations receiving awards under $500,000 may be exempt from full SAM.gov registration but still must obtain a UEI for transparency.
Primary recipients bear responsibility for ensuring their subrecipients secure UEIs before issuing subawards. Non-compliance may result in award disbursement delays or other enforcement actions.
Significantly, certain entities are exempt from UEI requirements, including individuals receiving assistance and second-tier subrecipients. To minimize disruptions, subrecipients should obtain UEIs early in the funding process and maintain updated organizational information in the system. Unlike primary recipients, subrecipients typically don’t need to configure EFT banking details within the SAM system, simplifying their registration requirements.
Frequently Asked Questions
Can International Entities Apply for a UEI Without a U.S. Presence?
Yes, international entities can apply for a UEI without having a physical U.S. presence.
Foreign entities are eligible to register in SAM.gov and obtain a UEI regardless of their geographic location. The international eligibility extends to organizations worldwide that wish to do business with the U.S. federal government.
These entities must still complete all required validation steps, provide appropriate documentation proving their existence, and may need to obtain an NCAGE code as part of the registration process.
What Documentation Is Needed for Entity Validation During SAM Registration?
Entity verification during SAM registration requires several documentation types.
Entities must provide proof of name and address through utility bills, bank statements, or tax filings.
For entity start year validation, organizations need certificates of incorporation, business licenses, or registration documents.
National identifier validation requires EIN documentation, tax returns, or government-issued IDs.
All documents must be current, with consistent information across submissions.
Non-English documents require self-certified English translations to meet documentation requirements.
How Are UEI Registration Issues or Validation Errors Resolved?
UEI validation errors are resolved through a systematic validation process.
When issues occur, entities should:
- Identify common errors like name/address mismatches or incomplete documentation
- Submit correct documentation in approved formats (PDF, JPG, BMP)
- Create a single incident ticket for review
- Monitor email for EVS requests within the 10-day review window
- Update SAM.gov profile with corrected information after validation is complete
Can One Entity Have Multiple UEIS for Different Departments?
No, a single legal entity cannot have multiple UEIs for different departments.
Federal regulations specifically prohibit departmental registrations under separate UEIs when they belong to the same legal organization.
SAM.gov assigns one UEI per legal entity regardless of its internal structure.
All departments, divisions, and branches must operate under the parent organization’s single UEI for federal award purposes, as this guarantees proper tracking and compliance with 2 CFR Part 25 requirements.
Are There Exemptions for Certain Types of Federal Funding Recipients?
Yes, certain recipients are exempt from UEI requirements. Federal agencies can exempt applicants from obtaining a UEI or registering in SAM.gov under specific conditions outlined in 2 CFR ยง25.110.
Exemptions typically apply to:
- Foreign organizations receiving awards under $500,000
- First-tier subrecipients (UEI required but not full SAM registration)
- Second-tier subrecipients
- Individuals receiving personal assistance
- Certain contractors
These funding exemptions are granted case-by-case, using risk-based assessments by the awarding agency.