Compliance in federal contracting is not a single event. It is a set of ongoing obligations that can drift out of date while everyone is focused on winning and performing work. The start of a new calendar year, when many businesses are already closing books and updating plans, is a convenient time for a structured review.
This checklist covers general areas many contractors review. Your obligations depend on your specific contracts and clauses, so treat it as a starting point and talk to a qualified professional about anything that applies to your situation.
Registrations and representations
- Is your SAM.gov registration active, with the expiration date on a shared calendar?
- Are your points of contact current?
- Do your NAICS codes and size representations reflect your situation today?
- Have any changes in ownership, address or banking been updated, and do they match IRS records?
Certifications and program status
- When are your next recertification or annual review dates for programs like 8(a), HUBZone, SDVOSB or WOSB?
- For HUBZone firms, does employee residency still meet the program requirement?
- Have any changes in ownership, management or affiliates affected eligibility?
- Do your capability statements and websites accurately describe your current certifications?
Contract-specific obligations
- Have you reviewed the clauses in each active contract and listed the recurring requirements, such as reports, deliverables and notifications?
- Are you tracking compliance with limitations on subcontracting on set-aside contracts?
- If you hold a GSA Schedule, are sales reporting and fee payments current, and is your catalog up to date?
- Have required flow-down clauses been included in your subcontracts?
- If you are a large business with subcontracting plans, are your reports on schedule?
Cybersecurity, labor and ethics
- If you handle federal contract information or controlled unclassified information, are your security practices documented and current with your contract requirements?
- For defense contractors, do you know where you stand on CMMC requirements that apply to your contracts?
- Are wage determinations and fringe benefit requirements being applied correctly on covered service or construction contracts?
- Do you have a written code of business ethics and conduct and an internal control system where your contracts require them?
- Have employees received any training your policies or contracts call for?
Records and readiness
- Are contract files, invoices, timesheets and correspondence organized and retained as required?
- Is your past performance library updated with last year’s work and current references?
- Have you reviewed recent CPARS evaluations and responded where appropriate?
- Are your accounting practices adequate for the contract types you hold or plan to pursue?
Assign an owner to each item and set dates for follow-up. A short compliance calendar, reviewed monthly, turns this list from a once-a-year exercise into a habit. Regulations change, so revisit current rules on acquisition.gov and sba.gov as part of your review.