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  • Question

    Is there a requirement, in this scenario, that requires a subcontractor be registered with SAM.gov? and, If the subcontractor remains a subcontractor and does not function as a prime, are they required to register?


    Answer

    FAR clause 52.204-7, System for Award Management (Oct 2016), is applicable to all solicitations unless one of exceptions at FAR 4.1102(a) exists.  Currently, I can find no requirement for a subcontractor to register in the System for Award Management (SAM) database solely due to their status as a subcontractor. 

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