FAR 52.204-15—Service Contract Reporting Requirements for Indefinite-Delivery Contracts.
Plain-English Summary
FAR 52.204-15 implements the service contract reporting requirements for indefinite-delivery contracts. It tells contractors when annual reporting is required for services performed under covered orders, what data must be reported, how and where the report is submitted, and what happens if the contractor misses the deadline or submits inaccurate information. The clause also requires agencies to review the reported data for reasonableness and gives the contractor a short window to revise the report or explain why no change is needed. In addition, it extends reporting down to first-tier subcontractors performing covered services, defines what counts as a first-tier subcontract versus a supplier agreement, and requires the prime contractor to tell subcontractors their data may be made public. In practice, this clause is a compliance and transparency mechanism: it supports government oversight of service contract labor usage and dollars, helps agencies monitor contract performance, and creates a public reporting trail for covered service work under indefinite-delivery vehicles.
Key Rules
Annual reporting required
The contractor must report annually by October 31 for services performed during the preceding Government fiscal year (October 1 through September 30). The reporting obligation applies only to orders under the contract that exceed the applicable threshold in FAR 4.1703(a)(2).
Required data elements
The report must include the contract number and order number, the total dollar amount invoiced for services performed during the prior fiscal year, the number of contractor direct labor hours expended, and any subcontractor data required by the clause. The focus is on services performed, not merely dollars obligated or ordered.
Submission through SAM
The required information must be submitted electronically through SAM.gov, using the SAM User Guide process. This makes the report a formal system-based compliance requirement rather than a paper or email submission.
Late or missing reports have consequences
If the contractor does not submit the report on time, the contracting officer may use appropriate contractual remedies. The contracting officer must also record the failure to comply in the contractor’s performance information under FAR subpart 42.15.
Agency review and correction cycle
Agencies must review contractor-reported information for reasonableness and consistency with available contract data. If revisions are needed, the agency must notify the contractor by November 15, and the contractor must revise the report or document its rationale by November 30.
First-tier subcontractor reporting
For covered first-tier subcontracts valued at or above the threshold, the prime contractor must require subcontractors to provide subcontract number, subcontractor name and unique entity identifier, and first-tier subcontractor direct-labor hours. The contractor must collect this information in time to meet the annual reporting deadline.
Public disclosure notice to subcontractors
The contractor must tell first-tier subcontractors that the information they provide will be made available to the public as required by section 743 of Division C of the Consolidated Appropriations Act, 2010. This notice requirement is part of the subcontract flowdown and transparency framework.
Definition of first-tier subcontract
A first-tier subcontract is one awarded directly by the contractor to acquire supplies or services, including construction, for performance of the prime contract. It does not include ordinary supplier agreements for materials or supplies that support multiple contracts or are normally treated as indirect or G&A costs.
Responsibilities
Contracting Officer
Ensure the clause is included when prescribed, monitor contractor compliance, apply appropriate contractual remedies if the report is late or missing, and record noncompliance in the contractor’s performance information under FAR subpart 42.15.
Agency
Review submitted reports for reasonableness and consistency with available contract information, notify the contractor by November 15 if revisions are warranted, and manage the correction process through November 30.
Contractor
Submit the annual report by October 31 through SAM.gov for covered orders, include all required contract, invoice, and labor-hour data, collect and report required first-tier subcontractor information, and revise the report or explain its rationale if the agency requests changes.
First-tier Subcontractor
Provide the prime contractor with the required subcontract identification information and direct-labor hours for covered services in sufficient time for the prime to meet the reporting deadline.
Contractor to Subcontractors
Advise first-tier subcontractors that the information they provide will be publicly available as required by the statute referenced in the clause.
Practical Implications
Contractors need a reliable internal process to capture direct labor hours and invoiced amounts by order and fiscal year; without that data, the SAM report will be incomplete or late.
The subcontract flowdown is operationally important: primes must identify covered first-tier subcontracts early and build reporting requirements into subcontract administration, not try to assemble the data at year-end.
The clause’s public-disclosure notice can affect subcontractor relationships, so primes should communicate this requirement up front when negotiating or awarding subcontracts.
Agencies are not just passively receiving data; they can challenge reported information and require corrections, so contractors should reconcile their report to contract records before submission.
Missing the October 31 deadline can trigger both contractual remedies and negative performance-record consequences, making this a compliance item with potential past-performance impact, not just a paperwork issue.
Official Regulatory Text
As prescribed in 4.1705 (b) , insert the following clause: Service Contract Reporting Requirements for Indefinite-Delivery Contracts (Oct 2016) (a) Definitions. First-tier subcontract means a subcontract awarded directly by the Contractor for the purpose of acquiring supplies or services (including construction) for performance of a prime contract. It does not include the Contractor’s supplier agreements with vendors, such as long-term arrangements for materials or supplies that benefit multiple contracts and/or the costs of which are normally applied to a Contractor’s general and administrative expenses or indirect costs. (b) The Contractor shall report, in accordance with paragraphs (c) and (d) of this clause, annually by October 31, for services performed during the preceding Government fiscal year (October 1-September 30) under this contract for orders that exceed the thresholds established in 4.1703 (a)(2). (c) The Contractor shall report the following information: (1) Contract number and order number. (2) The total dollar amount invoiced for services performed during the previous Government fiscal year under the order. (3) The number of Contractor direct labor hours expended on the services performed during the previous Government fiscal year. (4) Data reported by subcontractors under paragraph (f) of this clause. (d) The information required in paragraph (c) of this clause shall be submitted via the internet at www.sam.gov . (See SAM User Guide). If the Contractor fails to submit the report in a timely manner, the Contracting Officer will exercise appropriate contractual remedies. In addition, the Contracting Officer will make the Contractor’s failure to comply with the reporting requirements a part of the Contractor’s performance information under FAR subpart 42.15 . (e) Agencies will review Contractor reported information for reasonableness and consistency with available contract information. In the event the agency believes that revisions to the Contractor reported information are warranted, the agency will notify the Contractor no later than November 15. By November 30, the Contractor shall revise the report, or document its rationale for the agency. (f) (1) The Contractor shall require each first-tier subcontractor providing services under this contract, with subcontract(s) each valued at or above the thresholds set forth in 4.1703 (a)(2), to provide the following detailed information to the Contractor in sufficient time to submit the report: (i) Subcontract number (including subcontractor name and unique entity identifier), and (ii) The number of first-tier subcontractor direct-labor hours expended on the services performed during the previous Government fiscal year. (2) The Contractor shall advise the subcontractor that the information will be made available to the public as required by section 743 of Division C of the Consolidated Appropriations Act, 2010. (End of clause)