The End of the Continuous SAM Registration Requirement …. Almost

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.