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ARTICLE · 20 AUGUST 2025

FAR Final Rule Clarifies SAM Registration

Bass, Berry & Sims PLC
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On August 7, the Federal Acquisition Regulatory (FAR) Council issued a final rule, published in the Federal Register, clarifying that an offeror must be registered in the federal System...

United StatesGovernment, Public Sector
Richard W. Arnholt
Richard W. Arnholt

On August 7, the Federal Acquisition Regulatory (FAR) Council issued a final rule, published in the Federal Register, clarifying that an offeror must be registered in the federal System for Award Management (SAM) when submitting an offer and when the contract is awarded.

This revision mercifully ends the confusion that has reigned over the past few years, caused by a revision of the SAM registration requirement that was interpreted to render an offeror ineligible if its SAM registration lapsed at any time between submission of its offer and award.

Previous Amendments to FAR 52.204-7: System for Award Management

In September 2018, the FAR was amended to state that an "offeror is required to be registered in SAM when submitting an offer or quotation, and shall continue to be registered until time of award." Emphasis added.

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