FAR 4.604—Responsibilities.
Plain-English Summary
FAR 4.604 assigns responsibility for accurate and timely reporting of contract actions to the Federal Procurement Data System (FPDS). It covers three main areas: agency-level oversight by the Senior Procurement Executive and head of the contracting activity, the contracting officer’s responsibility for preparing, confirming, and correcting the individual Contract Action Report (CAR), and the annual agency certification of FPDS data completeness and accuracy by the chief acquisition officer. It also sets specific deadlines for completing CARs after award, including a standard three-business-day rule, a 30-day rule for certain actions under FAR 6.302-2 and subpart 18.2 authorities, and special update requirements for small business rerepresentation and SBA size protest decisions. In practice, this section is about data quality, accountability, and compliance: agencies must have a process to keep FPDS reporting current, and contracting officers must ensure the record matches the actual award and later status changes. Because FPDS data is used for oversight, reporting, and procurement analysis, errors or late entries can affect agency reporting integrity and create compliance issues.
Key Rules
Agency reporting process required
The Senior Procurement Executive, working with the head of the contracting activity, must develop and monitor a process that ensures contract actions are reported to FPDS accurately and on time. This is an agency management responsibility, not just an individual contracting officer task.
CO owns CAR accuracy
The contracting officer who awarded the action is responsible for the completion and accuracy of the individual CAR. A CAR left in draft or error status is not considered complete, so the record must be fully corrected and released.
Standard three-day deadline
For most awards, the contracting officer must confirm the CAR for accuracy before releasing the award and then complete the CAR in FPDS within three business days after contract award. This is the default reporting timeline.
Extended 30-day deadline for certain actions
For actions awarded under FAR 6.302-2 or under the authorities listed in subpart 18.2, the CAR must be completed in FPDS within 30 days after award. These actions receive a longer reporting window than the standard rule.
Update size status after rerepresentation
If the contracting officer receives written notice that the contractor has changed size status under the postaward rerepresentation clause at 52.219-28, FPDS must be updated within 30 days after receipt of that notice.
Update FPDS after SBA protest decision
If the contracting officer later receives SBA’s final decision on a size protest, FPDS must be updated to reflect that final decision. This ensures the system reflects the controlling size determination after award.
Annual certification required
Each agency’s chief acquisition officer must submit an annual certification to GSA, within 120 days after the end of the fiscal year, stating whether and to what degree the agency’s CAR data for the prior fiscal year is complete and accurate.
Responsibilities
Senior Procurement Executive
Develop and monitor an agency process that ensures contract actions are reported to FPDS in a timely and accurate manner.
Head of the Contracting Activity
Coordinate with the Senior Procurement Executive on the agency reporting process and help ensure the process is implemented and monitored effectively.
Contracting Officer
Prepare, verify, and ensure the accuracy of the CAR for each awarded action; confirm the CAR before award release; complete the CAR in FPDS within the required deadline; update FPDS when size status changes are reported or when SBA issues a final size protest decision.
Chief Acquisition Officer
Submit the annual certification to GSA within 120 days after the end of the fiscal year regarding the completeness and accuracy of the agency’s CAR data for the preceding fiscal year.
Agency
Maintain the systems, oversight, and internal controls needed to support accurate FPDS reporting and annual certification of data quality.
Practical Implications
Contracting officers need to treat FPDS reporting as part of award administration, not as an afterthought, because the CAR must be accurate before award release and completed quickly afterward.
The biggest compliance risk is late or incomplete reporting: draft or error-status CARs do not count as complete, and missed deadlines can undermine agency reporting and audit readiness.
Size status can change after award, so contracting officers must watch for rerepresentation notices and SBA protest outcomes and update FPDS promptly.
Agencies should have clear internal workflows and backup coverage so FPDS deadlines are met even when the contracting officer is unavailable.
Annual certification puts pressure on agencies to maintain clean data throughout the year; poor day-to-day reporting can create year-end certification problems and require corrective action.
Official Regulatory Text
(a) The Senior Procurement Executive in coordination with the head of the contracting activity is responsible for developing and monitoring a process to ensure timely and accurate reporting of contractual actions to FPDS. (b) (1) The responsibility for the completion and accuracy of the individual contract action report (CAR) resides with the contracting officer who awarded the contract action. CARs in a draft or error status in FPDS are not considered complete. (2) The CAR must be confirmed for accuracy by the contracting officer prior to release of the contract award. The CAR must then be completed in FPDS within three business days after contract award. (3) For any action awarded in accordance with FAR 6.302-2 or pursuant to any of the authorities listed at subpart 18.2 , the CAR must be completed in FPDS within 30 days after contract award. (4) When the contracting officer receives written notification that a contractor has changed its size status in accordance with the clause at 52.219-28 , Postaward Small Business Program Rerepresentation, the contracting officer shall update the size status in FPDS within 30 days after receipt of contractor’s notification of rerepresentation. (5) If after award of a contract, the contracting officer receives written notification of SBA’s final decision on a protest concerning a size determination, the contracting officer shall update FPDS to reflect the final decision. (c) The chief acquisition officer of each agency required to report its contract actions must submit to the General Services Administration (GSA), in accordance with FPDS guidance, within 120 days after the end of each fiscal year, an annual certification of whether, and to what degree, agency CAR data for the preceding fiscal year is complete and accurate.