The Federal Acquisition Regulatory Council (FAR Council) recently issued an interim rule clarifying the System for Award Management (SAM) registration requirements for federal contractors. Under this new rule, contractors no longer need to maintain continuous, uninterrupted SAM registration between the submission of their bid and the contract award. This addresses a contentious issue stemming from a 2018 FAR amendment, which was misinterpreted by courts and the Government Accountability Office to require ongoing SAM registration during the entire pre-award period.
The interim rule corrects this interpretation, stating that contractors only need to be registered in SAM at the time of bid submission and again at the time of award. The FAR Council emphasized that the amendment's intention was to ensure clarity regarding the timing of SAM registration, not to introduce new requirements with significant consequences for contractors. This change will relax the requirements on government contractors that did not have SAM registration status during the entire pre-award process. The rule became effective November 12, 2024.