Before the government can award you a contract — or pay you a dollar — your business must exist in the System for Award Management. FAR 52.204-7 requires an offeror to be registered in SAM when submitting an offer and at time of award, and "registered" is a defined term: Unique Entity ID issued, core data and representations complete, taxpayer identification number validated with the IRS, and the record marked Active. Registration is done at SAM.gov, it renews every 365 days, and — this cannot be said often enough — it is completely free.

The "free" point matters because an entire cottage industry preys on registrants. GSA's own fraud warnings describe spoofed SAM renewal emails and third-party firms charging fees — practitioners report hundreds to thousands of dollars — for something the government provides at no cost, often using publicly visible registration data — your UEI, CAGE code, and expiration date — to look official. If you want help, the Federal Service Desk at fsd.gov is free, and so are the DoD-funded APEX Accelerators.

What you need before you start

SAM's official checklist is short but unforgiving: your legal business name and physical address (no P.O. boxes) exactly as they appear on state formation documents; your EIN, matching your most recent IRS filing character for character; banking details for electronic funds transfer; a Login.gov account; and your NAICS codes. The Unique Entity ID — the 12-character identifier that replaced the DUNS number in April 2022 — is issued inside SAM.gov itself, so there is no third-party step anymore.

The step that trips up most new registrants is entity validation. Since 2022, SAM must validate your legal name and address against its verification service, and the automated match fails for mundane reasons: a brand-new LLC that has not propagated into the validation database yet, an ampersand where the state filing says "and," a missing suite number. When it fails, you create a documentation ticket from inside SAM.gov and attach stamped state formation filings or IRS documents — screenshots and lease agreements are rejected — then respond to the validation agent within five business days or the ticket closes and you start over. One ticket only; duplicates slow the queue. GSA's guidance is candid that manual review takes at least several days, and practitioners report weeks in bad cases. The official estimate for the whole registration is up to ten business days; plan for longer if validation goes sideways.

Your CAGE code — the five-character identifier maintained by the Defense Logistics Agency — is assigned automatically during registration for U.S. entities, and FAR 4.1803 confirms that an active SAM registration means the CAGE has been verified.

The lapse rule: what changed in 2024

For years, the most dangerous sentence in SAM was the requirement to be continuously registered from offer through award. GAO and the Court of Federal Claims enforced it without mercy — offerors lost contracts over registrations that lapsed for a single day mid-evaluation, through no fault beyond a slow renewal.

That era is over, and most older guides have not caught up. A FAR interim rule effective November 12, 2024 — finalized without change effective August 7, 2025 — removed the continuity requirement. You now must be registered at two points: when you submit your offer, and at award. A lapse in between, cured before award, no longer renders you ineligible. It remains a terrible idea to let registration lapse — FAR 52.204-13 still requires you to maintain it through performance and final payment, and an inactive registration halts payments, since your banking data lives in SAM — but the trapdoor that swallowed compliant proposals is closed.

Renewal, reps and certs, and staying alive

Registration expires 365 days after activation, and renewal reruns entity validation, so start early rather than the week before an offer is due. Your annual representations and certifications live in SAM too — under FAR 52.212-3, completing them electronically means most solicitations only need a confirmation that they are current and applicable, including your small-business self-certification against the size standards for the solicitation's NAICS code.

SAM itself has been moving: GSA rolled out a reorganized entity-registration workflow across mid-2025, and modernized FAR and DFARS representations and certifications went live on March 24, 2026, aligned with the ongoing FAR Overhaul. The data collected did not materially change, but screenshots in older tutorials no longer match the screens.

What It Means for Contractors

Treat SAM as infrastructure with a maintenance schedule, not a one-time form. Calendar renewal at least 60 days out; entity validation is the step you cannot expedite, and there is no premium lane. Before registering or renewing, reconcile three documents — your state filing, your last tax return, and your SAM record — because character-level mismatches between them cause most failures. Keep more than one person able to administer the record: recovering lost Entity Administrator access requires a notarized letter processed through the Federal Service Desk, which is exactly the paperwork you do not want between you and a proposal deadline.

If someone emails demanding payment to keep your registration active, it is a scam — forward it to the GSA Inspector General and move on. And if a competitor's award turns on registration timing, remember the current rule: registered at offer, registered at award. The one-day-lapse gotcha decisions that predate November 2024 are no longer good law, whatever an old blog post says.

Sources