FAR 4.1102—Policy.
Plain-English Summary
FAR 4.1102 sets the core policy for when offerors, quoters, and contractors must be registered in the System for Award Management (SAM) and how that registration information must be used in federal contracting. It explains the general rule that SAM registration is required at the time an offer or quotation is submitted so the offeror can satisfy annual representations and certifications, then lists specific exceptions for certain low-dollar, urgent, classified, overseas, emergency, and foreign-vendor situations. The section also addresses what contracting officers must do when an award is made under one of the exceptions, including when they should try to require SAM registration later. In addition, it governs how contracting officers must pull and use the contractor’s legal business name, DBA name, and physical address from SAM without alteration, which is important for accurate award documentation and data consistency. Finally, it covers SAM maintenance issues after award, including name changes, novation and change-of-name requirements, limits on changing EFT or payment information to reflect an assignee, and the need for assignees to register separately in SAM. In practice, this section is about identity control, payment integrity, and ensuring the government is dealing with the correct legal entity throughout the acquisition and contract administration lifecycle.
Key Rules
SAM registration at offer time
Offerors and quoters generally must be registered in SAM when they submit an offer or quotation in order to comply with annual representations and certifications requirements. This is the default rule for most acquisitions and is intended to ensure the government can rely on current entity information and certifications before award.
Exceptions to SAM requirement
The rule lists several situations where SAM registration is not required at submission, including certain micro-purchases using a Governmentwide commercial purchase card as both purchasing and payment mechanism, classified contracts, certain deployed/overseas/emergency contracting actions, contracts with individuals for work outside the United States and outlying areas, urgent sole-source awards under unusual and compelling urgency, certain low-dollar foreign vendor actions performed outside the United States when SAM registration is impractical, and some micro-purchases not paid by EFT and not reportable.
Post-award registration when practical
If a contract is awarded under the deployed, overseas, or emergency contracting exceptions, the contracting officer should modify the contract or agreement to require SAM registration if doing so is practical. The policy recognizes operational urgency but still seeks to bring the contractor into SAM when the situation stabilizes.
Use SAM data exactly as shown
Contracting officers must use the legal business name or DBA name and physical address from the contractor’s SAM record associated with the unique entity identifier. They may not change the data retrieved from SAM, which helps prevent mismatches between the award document, payment records, and the official entity record.
Name changes require notice and documentation
If a contractor legally changes its name or DBA name, or transfers assets used in performance before novation or a change-of-name agreement is completed, it must give the contracting officer at least one business day’s written notice before changing the SAM record, comply with subpart 42.12, and provide supporting documentation. The contractor must also agree in writing to the timeline and procedures set by the contracting officer.
Incorrect entity data can suspend payment
If the contractor does not follow the required name-change procedures, or if the SAM record shows a different contractor than the one named in the contract and there is no proper novation or change-of-name agreement, that SAM information may be treated as incorrect information under the EFT clause’s suspension-of-payment provision.
Assignment of claims limits
A contractor may not change the SAM EFT or manual payment name/address to reflect an assignee for purposes of assignment of claims. Assignees must register separately in SAM, and any SAM information suggesting payments should go to an ultimate recipient other than the contractor may be treated as incorrect information under the EFT clause.
Responsibilities
Offerors and Quoters
Register in SAM before submitting an offer or quotation unless a listed exception applies. Maintain accurate entity information, follow name-change notice requirements, and avoid using SAM payment data to redirect payments to an assignee.
Contracting Officer
Verify SAM registration status when required, use the legal business name/DBA and physical address exactly as shown in SAM, avoid altering SAM-derived data, and when practical modify certain emergency or deployed awards to require SAM registration later. The contracting officer also manages documentation and timing for name changes, novations, and change-of-name actions.
Contractor
Keep SAM information current, provide advance written notice and supporting documentation before changing the SAM name record in the absence of a completed novation or change-of-name agreement, comply with subpart 42.12, and ensure payment information is not improperly changed to reflect an assignee.
Assignee
Register separately in SAM and not rely on the contractor’s SAM record to receive payments or to be identified as the contractor under the contract.
Agency/Acquisition Team
Apply the correct exception when SAM registration is not required, ensure contract files and forms reflect the SAM data accurately, and support payment integrity and entity validation throughout award and administration.
Practical Implications
This section is a gatekeeper for award eligibility: if SAM registration is required and missing, the offeror or quoter may be ineligible for award or may face delays.
Contracting officers must be careful not to “fix” SAM data by editing it in the contract file; they must use the exact legal name, DBA, and address from SAM as retrieved.
The exceptions are narrow and situation-specific, so contractors should not assume that being overseas, urgent, or low-dollar automatically removes the SAM requirement.
Name changes, mergers, asset transfers, and assignments are high-risk areas; if the legal entity in SAM does not match the contract entity and there is no proper novation or change-of-name agreement, payment can be suspended.
For contractors operating in contingency, disaster, diplomatic, or other emergency environments, the government may award first and require SAM later, but the contractor should expect follow-up compliance once practical.
Official Regulatory Text
(a) Offerors and quoters are required to be registered in SAM at the time an offer or quotation is submitted in order to comply with the annual representations and certifications requirements except for— (1) Purchases under the micro-purchase threshold that use a Governmentwide commercial purchase card as both the purchasing and payment mechanism, as opposed to using the purchase card for payment only; (2) Classified contracts (see 2.101 ) when registration in SAM, or use of SAM data, could compromise the safeguarding of classified information or national security; (3) Contracts awarded by– (i) Deployed contracting officers in the course of military operations, including, but not limited to, contingency operations as defined in 10 U.S.C. 101(a)(13) or humanitarian or peacekeeping operations as defined in 10 U.S.C. 3015(2) ; (ii) Contracting officers located outside the United States and its outlying areas, as defined in 2.101 , for work to be performed in support of diplomatic or developmental operations, including those performed in support of foreign assistance programs overseas, in an area that has been designated by the Department of State as a danger pay post (see https://aoprals.state.gov/ );or (iii) Contracting officers in the conduct of emergency operations, such as responses to natural or environmental disasters or national or civil emergencies, e.g., Robert T. Stafford Disaster Relief and Emergency Assistance Act ( 42 U.S.C. 5121 ); (4) Contracts with individuals for performance outside the United States and its outlying areas; (5) Contracts awarded without providing for full and open competition due to unusual or compelling urgency (see 6.302-2 ); (6) Contract actions at or below $40,000 awarded to foreign vendors for work performed outside the United States, if it is impractical to obtain SAM registration; and (7) Micro-purchases that do not use the electronic funds transfer (EFT) method for payment and are not required to be reported (see subpart 4.6 ). (b) If practical, the contracting officer shall modify the contract or agreement awarded under paragraph (a)(3) of this section to require SAM registration. (c) Contracting officers shall use the legal business name or "doing business as" name and physical address from the contractor's SAM registration for the provided unique entity identifier to identify the contractor in section A of the contract schedule, similar sections of non-uniform contract formats and agreements, and all corresponding forms and data exchanges. Contracting officers shall make no changes to the data retrieved from SAM. (d) (1) (i) If a contractor has legally changed its business name or "doing business as" name (whichever is shown on the contract), or has transferred the assets used in performing the contract, but has not completed the necessary requirements regarding novation and change-of-name agreements in subpart 42.12 , the contractor is required to provide the responsible contracting officer a minimum of one business day's written notification of its intention to change the name in SAM, comply with the requirements of subpart 42.12 , and agree in writing to the timeline and procedures specified by the responsible contracting officer. Along with the notification, the contractor is required to provide the contracting officer sufficient documentation to support the legally changed name. (ii) If the contractor fails to comply with the requirements of paragraph (d)(1)(i) of the clause at 52.204-13 , System for Award Management Maintenance, or fails to perform the agreement at 52.204-13 , paragraph (d)(1)(i)(C), and, in the absence of a properly executed novation or change-of-name agreement, the SAM information that shows the contractor to be other than the contractor indicated in the contract will be considered to be incorrect information within the meaning of the "Suspension of Payment" paragraph of the EFT clause of the contract. (2) The contractor shall not change the name or address for electronic funds transfer payments (EFT) or manual payments, as appropriate, in the SAM record to reflect an assignee for the purpose of assignment of claims (see subpart 32.8 , Assignment of Claims). (3) Assignees shall be separately registered in SAM. Information provided to the contractor’s SAM record that indicates payments, including those made by EFT, to an ultimate recipient other than that contractor will be considered to be incorrect information within the meaning of the "Suspension of payment" paragraph of the EFT clause of the contract.