FAR 52.222-56—Certification Regarding Trafficking in Persons Compliance Plan.
Plain-English Summary
FAR 52.222-56 is the solicitation provision that requires an apparent successful offeror to certify, before award, that it has a trafficking-in-persons compliance plan for certain overseas work and that it has conducted due diligence regarding prohibited trafficking-related activities. It applies only to the portion of the contract, if any, that is for supplies other than COTS items to be acquired outside the United States, or services to be performed outside the United States, when that portion exceeds $700,000 in estimated value. The provision ties directly to FAR 52.222-50, Combating Trafficking in Persons, and specifically addresses the offeror’s obligation to prevent prohibited activities, monitor subcontractors, detect violations, and terminate subcontractors engaging in prohibited conduct. It also requires the offeror to certify either that neither it nor its proposed agents, subcontractors, or their agents are engaged in prohibited activities, or, if abuses have been found, that appropriate remedial and referral actions have been taken. In practice, this provision is a pre-award compliance gate for higher-risk overseas performance, designed to force contractors to document anti-trafficking controls before the Government makes an award.
Key Rules
Applies to specific overseas work
The certification requirement applies only to the portion of the contract, if any, that involves supplies other than COTS items acquired outside the United States or services performed outside the United States. It does not apply to all contract work automatically; the trigger is the overseas/non-COTS portion described in the provision.
Dollar threshold must be exceeded
The covered portion must have an estimated value that exceeds $700,000. If the overseas portion is at or below that threshold, this provision does not require the pre-award certification.
Certification is pre-award
The apparent successful offeror must submit the certification before award. This means the contracting officer should not proceed to award until the required certification is received and reviewed for the covered portion of the acquisition.
Compliance plan is required
The offeror must certify that it has implemented a compliance plan to prevent the prohibited activities identified in FAR 52.222-50(b). The plan must also provide for monitoring, detecting, and terminating subcontractors that engage in prohibited conduct.
Due diligence and knowledge statement
The offeror must certify, after conducting due diligence, either that neither it nor its proposed agents, subcontractors, or their agents is engaged in prohibited activities, or that any discovered abuses have been addressed through appropriate remedial and referral actions.
Covers subcontractor chain
The certification reaches beyond the prime contractor to proposed agents, subcontractors, and their agents. Contractors must therefore evaluate their supply chain and labor chain, not just their own direct operations.
COTS definition comes from 52.222-50
The term COTS item is not independently defined in this provision; instead, the provision incorporates the definition from the solicitation’s Combating Trafficking in Persons clause at FAR 52.222-50. Offerors must read the two provisions together.
Responsibilities
Contracting Officer
Identify whether the solicitation includes a covered overseas portion exceeding $700,000 and require the apparent successful offeror to submit the certification before award. The contracting officer should verify that the provision is included when prescribed and should not make award until the required certification is provided.
Apparent Successful Offeror
Prepare and submit the pre-award certification for the covered portion of the contract. The offeror must have a trafficking-in-persons compliance plan in place, conduct due diligence, and certify either that no prohibited activities are known or that any discovered abuses have been properly remediated and referred.
Prime Contractor / Offeror
Implement and maintain a compliance plan that prevents prohibited trafficking-related activities, monitors subcontractors, detects violations, and terminates subcontractors engaging in prohibited conduct. The prime must also assess its proposed agents and subcontractors before certification.
Proposed Subcontractors and Agents
Avoid engaging in any prohibited trafficking-related activities and cooperate with the prime’s due diligence and compliance efforts. If abuses are identified, they may need to support remedial actions and referrals as part of the prime’s compliance process.
Agency
Ensure the solicitation uses the provision when required by the prescription at FAR 22.1705(b) and support enforcement of trafficking-in-persons compliance requirements in overseas contracting.
Practical Implications
This provision is a pre-award checkpoint, so contractors need their compliance plan and supply-chain vetting ready before selection, not after award.
The $700,000 threshold applies only to the covered overseas portion, which can be easy to misread; contractors and contracting officers should analyze the specific portion of work, not just the total contract value.
Because the certification reaches subcontractors and their agents, weak subcontractor oversight is a common compliance risk, especially in labor-intensive overseas performance.
The certification is tied to FAR 52.222-50, so contractors must understand both the certification requirement and the underlying trafficking prohibitions, including monitoring and termination expectations.
If abuses are discovered, the provision does not automatically bar award, but it does require appropriate remedial and referral actions; contractors should document those actions carefully to support the certification.
Official Regulatory Text
As prescribed in 22.1705 (b) , insert the following provision: Certification Regarding Trafficking in Persons Compliance Plan (Oct 2025) (a) The term "commercially available off-the-shelf (COTS) item," is defined in the clause of this solicitation entitled "Combating Trafficking in Persons" (FAR clause 52.222-50 ). (b) The apparent successful Offeror shall submit, prior to award, a certification, as specified in paragraph (c) of this provision, for the portion (if any) of the contract that- (1) Is for supplies, other than commercially available off-the-shelf items, to be acquired outside the United States, or services to be performed outside the United States; and (2) Has an estimated value that exceeds $700,000. (c) The certification shall state that- (1) It has implemented a compliance plan to prevent any prohibited activities identified in paragraph (b) of the clause at 52.222-50 , Combating Trafficking in Persons, and to monitor, detect, and terminate the contract with a subcontractor engaging in prohibited activities identified at paragraph (b) of the clause at 52.222-50 , Combating Trafficking in Persons; and (2) After having conducted due diligence, either- (i) To the best of the Offeror’s knowledge and belief, neither it nor any of its proposed agents, subcontractors, or their agents is engaged in any such activities; or (ii) If abuses relating to any of the prohibited activities identified in 52.222-50 (b) have been found, the Offeror or proposed subcontractor has taken the appropriate remedial and referral actions. (End of provision)