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What SAM.gov shows the public about a registration, and what it does not

Which parts of a SAM.gov registration are public, which only government users can request, which are held as sensitive, and whether your EIN is among them, in GSA's own words.

Updated

SAM.gov shows a business's name, UEI, addresses, business types and codes to any authenticated user, and it keeps contact emails, phone numbers, bank details and tax numbers in tiers only a federal system account with the right permission can request. GSA's Entity Management API document sorts a record into three tiers: public, FOUO and sensitive. SAM.gov has discontinued the choice to opt out of public search, so a lookup that finds nothing reads as not found or opted out of public display, never as a verdict on the business.

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What does the public see in a SAM.gov entity record?

GSA's document for the Entity Management API, the interface that serves SAM.gov's entity data, describes its public tier as publicly available entities and their unclassified data. That covers name, UEI, registration details, physical and mailing addresses, business types, PSC and NAICS codes, and the name and address of each point of contact. SAM.gov's own registration pages say your registration status, legal business name, physical address and other non-sensitive information will be searchable to any authenticated user. GSA's page on registering a business adds that once a registration is active, the business becomes searchable governmentwide.

An entity does not need to be registered to be found. SAM.gov's comparison of its three purposes, shown while an entity is started, marks the entity as available in search for Unique Entity ID Only, Financial Assistance and All Awards alike. GSA's document has a request for the publicly available entities that have an identifier and no registration, which it calls ID Assigned. How to look up a business's UEI is how a prime contractor, a grant office or anyone else finds a record by legal name or by UEI.

Which parts can only government users request?

Only government users with the right permission can request a contact's email, phone and fax numbers. The document's second tier is labeled FOUO, a category of controlled unclassified information (CUI). It holds both the publicly available entities and the entities that opted out of public display. Its data includes the hierarchy, security levels for the company and its employees, and each point of contact's email address, phone and fax numbers. To request it, a user must have a federal system account with the Read FOUO permission. So a contact's name and address are in the public tier, and the contact's email, phone and fax numbers are not.

GSA's document for the extracts, the bulk files, says the same. The public entity extracts hold the publicly available entities and their unclassified data, which are available under the Freedom of Information Act (FOIA). The FOUO extracts add the entities that opted out of public display, and their FOUO data. The registration checklist SAM.gov publishes says non-sensitive entity information remains available to federal government users, and to those who download the SAM public data file.

Is my EIN public on SAM.gov?

No, your EIN is not in the tiers GSA's document calls public or FOUO. The third tier, sensitive data, covers every entity, whether its record is shown publicly or not. It holds banking information and the SSN, TIN or EIN. A user must have a federal system account with the Read Sensitive permission to request it. GSA's page on registering a business says SAM.gov collects taxpayer information because it is necessary to receive payment under a contract, collect debts and meet government reporting purposes.

This guide reports what GSA's documents say about SAM.gov's interface and nothing more. It says nothing about any other system or any other copy of the number. The public identifier of your business is the UEI, which anyone can look up. Is a UEI the same as an EIN? keeps the two apart.

Can a registration still opt out of public search?

No. SAM.gov used to offer the choice, and it does not now. The registration checklist SAM.gov publishes says publicly viewable entity records display the record status, legal business name and physical address. It says you can restrict the public viewing of your record by deselecting a checkbox. If you do, the record will not be visible to other non-federal entities or to state and local governments that may wish to do business with you. SAM.gov's registration pages now say it "has discontinued the opportunity to opt out of public search". The final review of a registration shows the search authorization fixed at yes, with nothing to choose.

GSA's API document still carries a field for whether an entity opted for public display or out of it. Its FOUO and sensitive tiers still include the entities that opted out. So a record kept out of public search under the earlier choice may still be hidden from a public lookup. That is why an empty result reads as not found or opted out of public display. What "not found or opted out of public display" means explains the reasons a lookup can come back empty.

What else becomes public through a registration?

Some reporting runs through the registration itself. Each year, a contractor that meets two revenue conditions, and whose executives' compensation is not already public through securities or tax filings, reports the names and total compensation of its five most highly compensated executives. That report is part of its SAM registration, and the law requires all reported information to be made public (FAR 52.204-10). The registration checklist asks the same questions in plain words, including whether the public already has access to information about the compensation of the senior executives.

The same clause has a prime contractor report each first-tier subcontract at or above a threshold. The report gives the subcontractor's unique entity identifier, name, address and award details, and that information is made public too (FAR 52.204-10). Do subcontractors need a SAM.gov registration, or only a UEI? covers what that means for a subcontractor.

What does a public lookup not prove?

A public lookup shows the public tier as it stood when it was read. It cannot see the FOUO or sensitive tiers, and it cannot see inside anybody's SAM.gov account. It cannot tell a record that does not exist from one kept out of public search, or from one whose identifier is not issued yet. An empty result is the absence of evidence, not a finding about the business. The record's owner is the one who can say why.

What does Firmenza read?

Firmenza's free health check reads the public tier of the Entity Management API, the same information anybody can search for, through the published interface, and the report says so on the page. It does not request the FOUO or sensitive tiers and has no field for them, so a report cannot display taxpayer or banking details. What the Firmenza health report checks, and what it does not lists what a report reads from the public record.

What can this guide not tell you?

GSA's tier descriptions say "such as", so they are examples and not a complete list of every field in each tier. This guide could not read the Federal Service Desk's articles on public search, SAM.gov's own help pages or the Privacy Act statement SAM.gov shows during a registration. It relies on GSA's API documents, the registration checklist, GSA's page on registering a business and SAM.gov's registration pages as read during a registration. Those sources do not say whether a record kept out of public search under the earlier choice is still hidden today.

Free help also exists: APEX Accelerators (DoD-funded, free) and the Federal Service Desk will help you at no charge. We built Firmenza to be useful alongside them.

Sources

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