Acquisition
SAM.gov, the UEI, and the CAGE code, explained
What SAM.gov registration includes, how the Unique Entity ID replaced the DUNS number on April 4, 2022, what the annual renewal covers, and how DLA assigns CAGE and NCAGE codes.
Oct 21, 20264 min read8 sources
Why it matters
FAR 52.204-7 requires an offeror to be registered in SAM when it submits an offer and at the time of award, and FAR 52.204-16 requires a CAGE code before award.
The short version
- 1On April 4, 2022, SAM.gov stopped using the 9-character DUNS number and made the 12-character Unique Entity ID (SAM) the authoritative identifier.
- 2SAM.gov registration must be renewed every 365 days, and FAR 4.1201 requires representations and certifications to be updated at least annually.
- 3The DLA CAGE Branch assigns U.S. CAGE codes during SAM registration; an entity outside the United States must get an NCAGE code before it registers.
SAM.gov, the System for Award Management, is the governmentwide site where a company or other entity registers to bid on federal contracts and apply for federal assistance. A registration carries two identifiers: the Unique Entity ID (UEI), which SAM.gov assigns, and the Commercial and Government Entity (CAGE) code, which the Defense Logistics Agency (DLA) assigns to locations in the United States. Under Federal Acquisition Regulation (FAR) 4.1102, offerors must be registered in SAM when they submit an offer or quotation, with listed exceptions. SAM.gov states on its Entity Registration page that a registration must be renewed every 365 days to stay active.
From DUNS to the Unique Entity ID
The UEI replaced the DUNS number. A General Services Administration (GSA) news release dated March 16, 2022 announced that on Monday, April 4, 2022, SAM.gov and all other GSA systems would switch to the Unique Entity ID (SAM) as the authoritative government entity identifier and stop using the DUNS number. The release says registered entities, active or not, had access to their new UEI since June 2021, and that SAM.gov had generated more than 2.5 million UEIs.
GSA's January 25, 2022 stakeholder forum slides give the difference in one comparison. The DUNS number was a 9-character numeric value managed, granted, and owned by Dun and Bradstreet. The UEI is a 12-character alphanumeric value managed, granted, and owned by the government. The slides add that the Office of Management and Budget (OMB) directed agencies to complete the transition no later than April 4, 2022.
An entity can get a UEI without registering. SAM.gov says a UEI alone needs only the legal business name and physical address, and suits transactions such as reporting as a sub-awardee, but an entity with only a UEI cannot apply directly for federal awards.
What a registration contains
The FAR 52.204-7 provision, in its November 2024 text, defines "registered in SAM" in four parts. The offeror has entered all mandatory information, including the UEI, the CAGE code, and data required by the Federal Funding Accountability and Transparency Act. The offeror has completed the Core, Assertions, Representations and Certifications, and Points of Contact sections. The Government has validated the mandatory fields, including the Taxpayer Identification Number (TIN) with the Internal Revenue Service. The Government has marked the record "Active."
SAM.gov's Entity Registration Checklist lists what goes into those sections, and states that SAM.gov is free to use, with no charge to get a UEI, register, or maintain a registration. Core data includes the TIN, banking details for electronic funds transfer, and ownership details. Representations and certifications include whether the entity or its principals are currently debarred, suspended, proposed for debarment, or declared ineligible.
The FAR Council's overhaul deviation text for part 4, last updated September 28, 2026, describes SAM as the primary method for collecting identifying information to issue the UEI and CAGE code, entity-level representations and certifications, and payment information.
The annual renewal and certifications
Two clocks run on a registration. SAM.gov requires renewal every 365 days. FAR 4.1201(b)(1) requires registrants to review and update their representations and certifications as necessary, but at least annually, and says they are effective until one year from submission or update. Under FAR 4.1201(b)(2), a contractor that represented itself as a small business before award must update its representations in SAM in accordance with clause 52.219-28. FAR 4.1201(c) requires the contracting officer to reference the date of SAM verification in the contract file.
During performance, the registration must stay current. FAR 52.204-7 points to clause 52.204-13 for maintaining registration through final payment. The FAR Council's overhaul text for part 4 adds that a contractor must tell the contracting officer of any change to its UEI or CAGE code within 30 days, and that a UEI change does not necessarily require a novation.
The CAGE code and the NCAGE
The FAR 52.204-16 provision, dated August 2020, defines two kinds of code:
- CAGE code. Assigned by the DLA CAGE Branch to an entity located in the United States or its outlying areas, to identify it by unique location. If a U.S. offeror has none, the branch assigns one as part of SAM registration. An offeror not registering in SAM may request one at cage.dla.mil.
- NCAGE code. Assigned by a member of the North Atlantic Treaty Organization (NATO) or by the NATO Support and Procurement Agency to an entity outside the United States, and recorded by DLA in the CAGE master file. SAM registrants outside the United States must obtain an NCAGE code before registering.
FAR 4.1802 requires an offeror to give the contracting officer the CAGE code for its location before award of a contract action above the micro-purchase threshold, and, if another entity owns or controls the offeror, that entity's CAGE code and legal name. Under FAR 4.1803, the contracting officer verifies the code through SAM. FAR 4.1800(b) notes that the UEI is a different identifier.
On classified work under the Security Requirements clause, 52.204-2, the same provision requires each subcontractor location listed on the DD Form 254 to carry its own CAGE code, unless the work is at a Government facility.
What to check
- Is the registration "Active," with the TIN validated and the Core, Assertions, Representations and Certifications, and Points of Contact sections complete?
- When was the registration last renewed, and does that fall within 365 days?
- Were the representations and certifications updated within the past year, as FAR 4.1201(b)(1) requires?
- Does the CAGE code on the offer match the name and location address it was assigned to?
- For an entity outside the United States, was an NCAGE code obtained before the SAM registration began?
- Does a document still cite a DUNS number, which SAM.gov stopped using on April 4, 2022?
Sources
- 1GSA Systems Switch to Unique Entity ID (SAM) on April 4, 2022 · U.S. General Services Administration (news release, March 16, 2022)
- 2IAE Stakeholder Forum: Getting a Unique Entity ID (SAM), January 25, 2022 · U.S. General Services Administration, Integrated Award Environment
- 3Entity Registration · SAM.gov, U.S. General Services Administration
- 4Entity Registration Checklist · SAM.gov, U.S. General Services Administration
- 5FAR Part 4 - Administrative and Information Matters · Acquisition.gov (FAC 2026-01, effective March 13, 2026)
- 652.204-7 System for Award Management · Acquisition.gov (provision dated November 2024)
- 752.204-16 Commercial and Government Entity Code Reporting · Acquisition.gov (provision dated August 2020)
- 8FAR Overhaul - Part 4 · Acquisition.gov, Revolutionary FAR Overhaul deviation guidance (last updated September 28, 2026)
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