The Complete Federal Contractor Compliance Checklist (2025)

Federal contracting compliance is not a one-time event — it is an ongoing operational requirement. Registration lapses, expired certifications, missed reporting obligations, and outdated accounting practices are the most common reasons contractors face payment delays, contract disputes, and debarment proceedings.

This checklist covers the full range of federal contractor compliance obligations, organized by category. Use it to audit your current compliance posture and identify gaps before they become problems.

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Section 1: Registration and System Access

SAM.gov Registration

• Active SAM.gov entity registration (verify expiration date — renew annually)
• Correct UEI (Unique Entity Identifier) on all correspondence and invoices
• Current CAGE code active and accurate
• Primary NAICS code correct and reflects actual business capabilities
• All applicable NAICS codes listed in SAM.gov profile
• EFT (Electronic Funds Transfer) banking information current and correct
• Representations and Certifications (Reps and Certs) current — review at each annual renewal
• DUNS-to-UEI transition complete (if your company pre-dates 2022)

DSBS (Dynamic Small Business Search)

• SBA profile complete and accurate in DSBS
• Capability narrative updated to reflect current services
• Contact information current

WAWF/IPP Access

• WAWF.eb.mil access established (DoD contracts)
• IPP.gov access established (civilian agency contracts)
• Correct DoDAAC codes on file for active DoD contracts
• ECA certificate or CAC access current for WAWF

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Section 2: Small Business Certifications

Small Business Self-Certification

• Size standard verified for each primary NAICS code
• Affiliation analysis conducted (any teaming, subsidiaries, or investment relationships that could affect size?)
• Annual recertification completed in SAM.gov

Program Certifications (if applicable)

• 8(a): SBA certification active; expiration date tracked; annual review submission current
• HUBZone: Certification active; 35% employee residency requirement verified; principal office in designated zone
• SDVOSB/VOSB: SBA certification active (post-2023, SBA — not VA — certifies); VIP database status verified
• WOSB/EDWOSB: SBA certification active; economic disadvantage documentation current
• SBA recertification triggers: Any change in ownership, size, or structure should trigger a voluntary recertification review

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Section 3: Labor Law Compliance

Fair Labor Standards Act (FLSA)

• All workers correctly classified: employee vs. independent contractor
• Non-exempt employees receiving overtime (1.5x) for hours over 40/week
• Minimum wage compliance (federal and state — whichever is higher)
• Child labor laws complied with if applicable

Service Contract Act (SCA) — If applicable

• Current Wage Determinations obtained and applied for all SCA-covered contracts
• Health & Welfare fringe benefit rate (currently $4.98/hr for 2024) paid for all hours paid
• Federal holidays (11) provided as paid holidays for covered workers
• Vacation accrual policy compliant with SCA minimums (1 week after 1 year, 2 weeks after 5 years)
• Payroll records maintained for 3 years
• SCA notice posted at worksites

Davis-Bacon Act (DBA) — If applicable to construction contracts

• Prevailing wage rates from current Wage Determination applied
• Weekly certified payroll reports submitted per DBA requirements
• Apprentice ratios maintained if required

Executive Order Compliance

• E.O. 13658/13706: Minimum wage on federal contracts — $17.75/hour in 2024 for new awards
• E.O. 14026: Contractor minimum wage — verify current applicable rate
• Paid sick leave (E.O. 13706): 1 hour per 30 hours worked; 56 hours annually
• E.O. 11246 / VEVRAA / Section 503: Affirmative Action Plan if required (50+ employees on $50K+ contract)

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Section 4: Cybersecurity Compliance

For All Contractors

• FAR 52.204-21 (Basic Safeguarding) controls implemented if any federal contract information is handled
• Incident reporting procedures in place

For DoD Contractors Handling CUI

• DFARS 252.204-7012 clause in all applicable contracts identified
• NIST SP 800-171 gap assessment completed
• System Security Plan (SSP) documented and current
• SPRS score entered and accurate (reflects honest assessment)
• 72-hour incident reporting capability established
• Plans of Action & Milestones (POA&Ms) for unimplemented controls documented and being remediated

For CMMC (when required)

• CMMC level required by your contracts identified
• Level 1: Annual self-assessment submitted to SPRS
• Level 2: C3PAO assessment scheduled and completed
• Level 3: DCSA-led assessment completed

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Section 5: Financial and Accounting Compliance

Accounting System

• Accounting system correctly segregates direct costs from indirect costs
• Indirect cost pools (Fringe, Overhead, G&A) properly structured
• Unallowable costs (FAR 31.201) segregated from allowable costs
• Job-cost tracking by contract number operational

Cost-Reimbursement Contracts

• Provisional billing rates established with ACO
• Incurred Cost Submission (ICS) submitted within 6 months of each fiscal year end
• DCAA accounting system pre-award survey passed (if required for new CPSR)

Truth in Negotiations

• TINA certifications accurate for all proposals over $2 million
• Cost or pricing data submitted is current, accurate, and complete

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Section 6: Contract Performance Obligations

During Contract Performance

• Contracting Officer Representative (COR) contact information current
• All contract deliverables tracked against CDRL
• WAWF/IPP invoices submitted on time and for correct amounts
• Government-furnished property tracked and accounted for

Reporting Requirements

• Small business subcontracting plan reports submitted on schedule (ISR/SSR in eSRS)
• Contractor compliance certifications (DBE, SCA, wage compliance) submitted as required
• Patent and IP reports submitted at milestones if R&D contract
• FFATA reporting (for grants/contracts over $25,000): first-tier subawards reported

Performance Records

• CPARS assessments reviewed within 14-day window
• Contractor comments submitted when ratings require response
• Performance documentation maintained (deliverable acceptance letters, COR feedback)

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Section 7: Trade Compliance

Buy American Act / Trade Agreements Act

• Products sold to the government verified as TAA-compliant (originating in US or TAA-eligible country)
• Country-of-origin certifications obtained from manufacturers in writing
• Non-TAA products excluded from federal sales catalog (GSA Schedule and commercial invoices to agencies)

Export Controls (if applicable)

• ITAR/EAR classifications completed for all products and technologies
• Export licenses obtained where required
• Deemed export awareness training for foreign national employees
• Technology control plan in place for ITAR-controlled facilities

Berry Amendment (DoD only)

• Specialty metals of US origin verified for DoD supply contracts
• Clothing, food, and hand tools of domestic origin for DoD

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Section 8: Ethics and Procurement Integrity

• Code of Business Ethics and Conduct implemented (FAR 52.203-13 if contract ≥$5.5M, 120+ day PoP)
• Employee ethics training conducted
• Hotline poster displayed (or reference to hotline in policy)
• Procurement Integrity Act awareness — no improper solicitation of employment from government officials
• OCI (Organizational Conflict of Interest) screening before each new pursuit
• No prohibited source relationships (gifts over $20 threshold to government employees)

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Annual Compliance Calendar

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Key Takeaways

• SAM.gov annual renewal is the single most critical administrative obligation — a lapsed registration stops payments and can prevent award.
• SCA and Davis-Bacon wage compliance require active management at the start of every new fiscal year — wage determinations change.
• NIST 800-171 / SPRS compliance is not optional for DoD CUI contracts — inaccurate self-certification is a False Claims Act risk.
• ICS submission (within 6 months of fiscal year end) is required for all cost-reimbursement contracts — missing it delays contract closeout and final payment.
• CPARS 14-day window is a hard deadline — set a calendar alert when you receive the draft assessment notification.
• This checklist is a starting point — large or complex contracts may have additional compliance requirements specific to the agency, program, or contract type.

Stay on top of federal contracting opportunities while managing your compliance obligations →