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GSA Issues Notice of “Glitch” and Recommends Contractors Validate Small Business Status Representations on SAM.gov

Client Alert | 1 min read | 09.17.26

The General Services Administration (GSA) has begun sending out email notifications of a “known glitch” affecting certain System for Award Management (SAM) registrations as far back as spring 2026.  

The “glitch” has resulted in inaccurate or missing data under the FAR 52.219-1 Small Business Program Representations for some SAM registrants. The data inputs for NAICS codes and associated size standard representations have “reset” for affected entities, meaning that SAM displays “N/A” instead of the requisite “Yes” or “No” to indicate whether the entity is certifying as small under the applicable NAICS code.  

GSA recommends, as does Crowell, that contractors review the Representations and Certifications section within their SAM.gov registrations as soon as practicable to verify that their small business and socioeconomic status representations under FAR 52.219-1 are accurate. Any NAICS code marked as N/A should be updated to reflect “Yes” or “No” by re-entering the entity’s receipts and employee count (aggregated across all affiliates and measured over the appropriate period). It is critical to confirm the completeness of SAM to avoid compliance issues related to small business certifications as well as to ensure eligibility for pending or upcoming awards. 

Note, while the GSA notice states that contractors should correct this issue as part of a “Re-certify and update” process, our understanding is not that any entity must recertify its size or status against any particular contract (which could implicate on-going eligibility).  Rather, entities must simply re-verify and update their certifications on SAM in order to correct any errors on SAM resulting from the “glitch.” 

Insights

Client Alert | 4 min read | 09.16.26

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