FAR 23.501—Policy.
Plain-English Summary
FAR 23.501 establishes a greenhouse gas (GHG) disclosure policy tied to federal procurement. It applies to offerors that are registered in the System for Award Management (SAM) and that received $7.5 million or more in Federal contract awards in the prior Federal fiscal year. The section requires those offerors to make specific representations about whether they publicly disclose their greenhouse gas emissions and whether they publicly disclose a quantitative greenhouse gas emissions reduction goal, and to provide the website for any such disclosures. In practical terms, this policy is designed to help the Government better understand both direct and indirect emissions associated with Federal contracting activity and to improve visibility into contractor climate-related transparency and commitments. For contractors, the rule creates a recurring compliance and proposal-preparation obligation; for contracting personnel, it adds a screening and documentation point that may affect responsibility determinations, solicitation responses, and award processing. The section is narrow in scope but important because it links environmental reporting expectations to eligibility and representation requirements in the procurement process.
Key Rules
Applies to large-award offerors
The policy applies only to offerors that are registered in SAM and received $7.5 million or more in Federal contract awards in the prior Federal fiscal year. Smaller contractors outside this threshold are not covered by this specific requirement.
Must represent GHG disclosure status
Covered offerors must state whether they publicly disclose greenhouse gas emissions. The rule is a representation requirement, so the offeror must affirmatively indicate its status rather than remain silent.
Must represent emissions-reduction goals
Covered offerors must also state whether they publicly disclose a quantitative greenhouse gas emissions reduction goal. This focuses on whether the contractor has a measurable public target, not merely a general sustainability statement.
Website must be provided
If the offeror makes either type of public disclosure, it must provide the website where that disclosure can be found. This allows the Government to verify the representation and review the underlying information.
Purpose is emissions visibility
The policy exists to help the Government better understand both direct and indirect greenhouse gas emissions resulting from Federal activities. The disclosure requirement is intended to improve transparency and support informed procurement and policy decisions.
Responsibilities
Offeror / Contractor
Determine whether it is registered in SAM and whether it received $7.5 million or more in Federal contract awards in the prior Federal fiscal year. If covered, it must represent whether it publicly discloses greenhouse gas emissions, represent whether it publicly discloses a quantitative greenhouse gas emissions reduction goal, and provide the website for any such disclosures.
Contracting Officer
Ensure the solicitation and award process captures the required representations from covered offerors and that the information is available for evaluation or administrative review as required by agency procedures. The contracting officer should also verify that the offeror’s responses are complete and consistent with the solicitation requirements.
Agency / Procurement Staff
Implement the policy in procurement systems and solicitation templates, track whether the threshold and SAM-registration conditions apply, and maintain the information needed to support compliance and reporting. Agencies may also use the disclosures to inform broader sustainability and acquisition planning efforts.
Practical Implications
Contractors near or above the $7.5 million threshold should expect this to be a recurring proposal and registration check, not a one-time exercise.
A common pitfall is failing to keep SAM registration current or overlooking whether prior-year Federal awards trigger the rule.
Another frequent issue is confusing a general sustainability statement with a quantitative emissions-reduction goal; the rule asks for a specific public goal if one exists.
If a disclosure exists, the website link should be accurate and publicly accessible, since the Government may use it to verify the representation.
Contracting officers should watch for incomplete responses or mismatches between the representation and the cited website, especially where the disclosure is posted on a corporate sustainability page rather than a dedicated GHG report.
Official Regulatory Text
In order to better understand both direct and indirect greenhouse gas emissions that result from Federal activities, offerors that are registered in the System for Award Management (SAM) and received $7.5 million or more in Federal contract awards in the prior Federal fiscal year are required to— (a) Represent whether they publicly disclose greenhouse gas emissions; (b) Represent whether they publicly disclose a quantitative greenhouse gas emissions reduction goal; and (c) Provide the website for any such disclosures.