Small Business Registration Rule Update
Summary
This document is issued under the joint authority of OFPP, DoD, GSA, and NASA. This Small Entity Compliance Guide has been prepared in accordance with section 212 of the Small Business Regulatory Enforcement Fairness Act of 1996. It consists of a summary of the rules appearing in Federal Acquisition Circular (FAC) 2025-05, which amends the Federal Acquisition Regulation (FAR). Interested parties may obtain further information regarding these rules by referring to FAC 2025-05, which precedes this document.
Compliance Requirements
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Offerors are required to be registered at the time of proposal submission and at time of award, rather than continuously in between.
Market Impacts
The change in System for Award Management preaward registration requirements from continuous registration to registration at the time of proposal submission and at time of award is expected to have a positive impact on small businesses who have a minor lapse in registration.; Offerors are required to be registered in the System for Award Management at the time of proposal submission and at time of award.
Validated Company Impacts
ASGN Inc
ASGN's Federal Government Segment, representing 30% of revenue, directly engages in federal procurement activities where this rule applies to offerors. The company's IT services and solutions delivery to government agencies requires compliance with Federal Acquisition Regulation requirements for proposal submission and award registration.
Science Applications International Corp
SAIC operates exclusively as a government contractor and subcontractor for federal agencies, primarily through the U.S. government procurement system. The rule specifically targets offerors in federal procurement markets, which directly aligns with SAIC's core business model of submitting proposals and receiving awards for government contracts.
TYLER TECHNOLOGIES INC
Tyler Technologies is a leading provider of integrated software and technology solutions specifically for the public sector, including federal government entities, which directly operates in federal procurement markets targeted by this FAR rule. The company's business model involves providing technology solutions to government agencies that would require compliance with federal acquisition regulations when bidding on contracts.
WillScot Holdings Corp
The rule directly addresses federal procurement compliance requirements that align with the company's identified 'US Government Contract Laws' risk, which specifically mentions increased costs and liability exposure under government contract regulations. The registration timing change could mitigate the company's regulatory compliance risks related to proposal submissions and contract awards.
CACI INTERNATIONAL INC /DE/
CACI International operates extensively in federal procurement markets, providing technology and expertise to government agencies, which directly aligns with the FAR requirements for offeror registration in the System for Award Management. The company's business model of delivering services to domestic government customers places it squarely within the scope of this federal acquisition regulation.
AECOM
AECOM operates extensively in federal procurement markets through its Americas segment, providing planning, advisory, consulting, and engineering services to public clients including US government agencies. The company would be directly affected by the System for Award Management registration requirements as an offeror for federal contracts.
Leidos Holdings, Inc.
Leidos Holdings operates extensively in federal government contracting through its Defense Solutions segment, directly engaging in federal procurement activities that require System for Award Management registration. The company's core business model involves submitting proposals and receiving awards from federal agencies, making it directly subject to the rule's registration timing requirements.
MAXIMUS, INC.
MAXIMUS operates exclusively in government services with its U.S. Federal Services Segment ($3M revenue) directly involved in federal procurement through program operations and management for U.S. federal agencies. The rule specifically targets offerors in federal procurement markets, which aligns perfectly with MAXIMUS's core business of delivering solutions to federal government agencies.
Palantir Technologies Inc.
Palantir Technologies has significant government operations serving defense agencies and the intelligence community, which heavily rely on federal procurement contracts. The company's business model involves bidding for and securing government contracts, directly aligning with the FAR requirements for System for Award Management registration at proposal submission and award stages.
PARSONS CORP
Parsons Corp is a major federal government contractor that regularly submits proposals and receives awards for federal acquisition contracts across defense, intelligence, and civilian agencies. The company's core business model involves competing for and executing federal contracts, making it directly subject to System for Award Management registration requirements at both proposal submission and award stages.
VSE CORP
VSE Corporation operates as a government contractor providing aftermarket parts distribution and MRO services to government markets, making it subject to Federal Acquisition Regulation requirements. The company's business model involves submitting proposals and receiving awards for federal contracts, directly aligning with the rule's registration requirements at proposal submission and award times.