The End of the Continuous SAM Registration Requirement …. Almost
Client Alert | 1 min read | 08.12.25
On August 7, 2025, the FAR Council issued a final rule amending FAR 52.204-7 to clarify that, effective immediately, an offeror’s failure to maintain continuous System for Award Management (SAM) registration between proposal submission and contract award does not render the offeror ineligible for award, so long as the offeror was registered in SAM at the time of proposal submission and is registered at the time of contract award. The final rule should address situations like TLS Joint Venture, LLC, B-422275, Apr. 1, 2024, 2024 CPD ¶ 74, where an offeror’s SAM registration lapsed for a single day between the proposal submission and award dates, and GAO found the offeror ineligible for award.
This rule change represents common-sense reform and should provide welcome relief to the government contractor community. But a note of caution is in order. While the change to FAR 52.204-7 will be implemented in solicitations issued after the August 7, 2025 effective date, existing solicitations will largely still mandate compliance with the prior continuous SAM registration rule, unless the agency amends the solicitation. For that reason, contractors competing under solicitations issued prior to August 7, 2025 should continue to closely monitor their SAM registration status to ensure eligibility for contract award.
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Client Alert | 3 min read | 06.03.26
Important EU Court Judgment Clarifies Rules on Interest Due in Cartel Damages Cases
In a judgment that will have direct and immediate consequences, the Court of Justice of the European Union (CJEU) has clarified that for all competition damages actions brought after 26 December 2014, interest runs from the date on which the harm occurred. The ruling addressed two important questions: (1) whether national provisions implementing Article 3(2) of the EU Damages Directive — which requires interest to run from the date harm occurred —apply to cases in which the harm preceded the adoption of those provisions; and (2) how the date of harm should be determined in cartel cases involving the purchase of goods at inflated prices.
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California Assembly Passes AB 1776, Sending Major Antitrust Bill to the Senate
