FAR rule change clarifies that companies need to be registered in SAM *prior* to submitting an offer

A final rule was published in the Federal Register today, amending the Federal Acquisition Regulation (FAR) to update the instructions for registration in the System for Award Management (SAM) and clarify the timing of registration in SAM. The new rule, which is effective October 26, 2018, requires all offerors (except as provided at FAR 4.1102) to be registered in SAM at the time of submission of an offer or quotation. Currently there is language in the FAR which states that prospective contractors shall be registered in SAM prior to contract award (with some exceptions), but there are provisions in other parts of the FAR that have generally made registration in SAM at the time of offer the de facto requirement. With this rule change, these inconsistencies have been cleared up, and offerors will need to be registered in SAM when they submit their offer.