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ARTICLE · 13 AUGUST 2025

No Change Here: SAM Registration Interim Rule Has Been Fully Adopted

Taft, Stettinius & Hollister LLP
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As discussed in a prior bulletin, the Federal Acquisition Regulatory Council (FAR Council) issued an interim rule in November clarifying that offerors are not required to be registered...

United StatesGovernment, Public Sector
Suzanne Sumner
Suzanne Sumner
Celeste M. Friel
Celeste M. Friel
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As discussed in a prior bulletin, the Federal Acquisition Regulatory Council (FAR Council) issued an interim rule in November clarifying that offerors are not required to be registered in the System for Award Management (SAM) database from the moment of bid/proposal submission through contract award. The FAR Council stated that this change was intended to correct misinterpretations surrounding the September 2018 amendment to the Federal Acquisition Regulation, which required contractors to have "continuous, uninterrupted" active registration through the entire contractual pre-award process.

On Aug. 6, the Federal Acquisition Regulatory Council issued a final rule that fully adopts the interim rule. Federal contractors are not required to be continuously registered in SAM between the date of bid/proposal submission and contract award to be eligible for award.

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