SAM registration is mandatory for all entities seeking federal contracts, grants, or financial assistance. Organizations including businesses, nonprofits, educational institutions, local governments, and tribal entities must register. Registration requires obtaining a Unique Entity ID (UEI) through SAM.gov and creating a login.gov account. Some exemptions exist under 2 CFR 25.110, including foreign vendors with contracts under $30,000 awarded outside the U.S. The process typically takes 2-8 weeks, requiring advance planning and documentation preparation.
Core Eligibility Criteria for SAM Registration
When entities seek to conduct business with the federal government, they must meet specific registration requirements through the System for Award Management (SAM). Federal regulations, specifically 2 CFR Part 25, mandate registration for all organizations planning to apply for federal contracts, grants, or financial assistance.
This requirement spans across all organization types, including local governments, tribal entities, nonprofits, businesses, and educational institutions.
The application process involves obtaining a Unique Entity ID (UEI) through SAM.gov, which serves as the foundation for entity validation. Creating a login.gov account is a prerequisite step before beginning the SAM registration process. Foreign entities pursuing federal funding must also register with a valid UEI.
Even sole proprietorships require registration when seeking federal contracts or assistance. Registration benefits include eligibility for federal awards, electronic payment processing, and access to federal procurement opportunities. It’s important to note that registration renewal must occur at least every 12 months to maintain compliance with federal requirements.
Organizations must maintain active registrations throughout the application review and award phases to remain eligible for federal funding.
Exemptions and Special Cases: Who Doesn’t Need to Register
While most entities must complete SAM registration to engage with federal government opportunities, specific exemptions exist for certain organizations and circumstances. The exemption criteria primarily apply to organizations that do not receive federal contracts or those that qualify under provisions in 2 CFR 25.110.
Several special cases include federally funded research projects with unique reporting requirements, tribal organizations requiring specific documentation, and religious corporations subject to particular law-based exemptions. Additionally, disaster relief participants may receive exemptions when providing immediate aid. Foreign vendors with contracts under $30,000 awarded outside the United States are also exempt from the SAM registration requirement.
Exemptions often depend on funding purpose, transaction type (grants versus contracts), and program-specific guidelines. For instance, small grants or non-U.S. entities may face different requirements based on contract terms.
It’s important to note that exemptions do not eliminate other compliance obligations. Nonprofit organizations may face unique considerations when determining their SAM compliance status. Organizations should verify their exemption status, possibly with legal counsel, as SAM registration remains mandatory for most federal funding transactions.
Registration Timeline: When to Complete Your SAM Profile
Securing a timely System for Award Management (SAM) registration requires careful planning well before any federal opportunity deadlines.
Effective SAM registration demands strategic advance planning to meet federal contracting deadlines.
The complete registration timeline typically spans 2-8 weeks, making early preparation essential for successful participation in government contracting.
The preparation phase begins with gathering required documentation, including your EIN/TIN, which alone can add 5+ weeks if not already established.
Allow approximately 45 minutes for initial form completion, plus additional time for notarized letter preparation and document collection. Entities should submit a notarized letter for the Entity Administrator as this is a mandatory requirement for new registrations.
A strategic approach to the SAM renewal process is critical for maintaining continuous eligibility for federal contracts and grants without disruptions.
Once submitted, expect:
- 7-10 business days for standard processing
- No same-day approvals under any circumstances
- Possible delays during fiscal year-end periods
For ideal results:
- Begin at least 90 days before your first bidding opportunity
- Schedule renewal 30 days before the 365-day expiration
- Monitor your application through the SAM Status Tracker
- Address any bank validation issues promptly
Frequently Asked Questions
Can International Entities With No U.S. Presence Register in SAM?
Yes, international registration is available for foreign entities with no U.S. presence.
These organizations can register in SAM by obtaining a DUNS number and an NCAGE code prior to creating a SAM.gov account.
During registration, they must provide their legal business name and physical address for verification.
While U.S.-based TIN information is only required if the entity pays U.S. taxes, a notarized letter appointing an Entity Administrator is typically needed for validation.
How Do Mergers or Acquisitions Affect Existing SAM Registrations?
During mergers or acquisitions, SAM registrations require careful management.
Acquisition processes may allow for registration transfers between entities, provided the new organization meets eligibility requirements.
Merger implications include potential changes to contract eligibility and performance status.
Both entities must notify SAM administrators about the change, undergo verification, and update business information post-transfer.
Failing to properly manage registration transfers can jeopardize existing government contracts and future award opportunities.
Is SAM Registration Required for Subcontractors on Federal Projects?
Subcontractor requirements for SAM registration on federal projects vary by circumstance.
Unlike prime contractors, subcontractors are generally not required to register in SAM unless specifically mandated in contract terms.
Federal compliance guidelines allow flexibility, with exceptions including state-administered federal funds and micro-purchases under simplified acquisition thresholds.
However, agency-specific clauses may override these exemptions.
Some contracts may require registration before invoice submission or within a specified timeframe after contract award.
What Happens if My SAM Registration Expires During Contract Performance?
When a SAM registration expires during contract performance, it creates serious contract compliance issues.
The contractor may face payment delays, inability to receive contract modifications, and potential breach of FAR requirements. While existing contracts aren’t automatically terminated, the registration consequences include operational disruptions and possible contract termination if not promptly renewed.
Agencies cannot process modifications for scope changes or funding adjustments until the registration is active again. Renewal should be prioritized immediately.
Are There Fees Associated With SAM Registration or Renewal?
There are no fees associated with the SAM registration process or renewal timeline. The official SAM.gov system is completely free for all entities.
Organizations should be cautious of third-party scams requesting payment for registration or renewal services. The Federal Service Desk provides complimentary support at 866-606-8220.
While the process typically takes up to 10 business days to complete, no expedited payment options exist for faster processing.