The differences at a glance
| Suspension | Proposed debarment | Debarment | Voluntary exclusion | |
|---|---|---|---|---|
| What it is | Temporary, pending investigation or legal proceedings | Notice that debarment is being considered | Exclusion after a decision | An agreement to be excluded |
| Evidence | Adequate evidence; an indictment counts | The notice starts the process | Preponderance of the evidence, unless based on a conviction or civil judgment | The agreement itself |
| How long | Ends after 12 months without legal proceedings, extendable by 6; no more than 18 unless proceedings have started | Until the debarring official decides | Generally no more than 3 years, with exceptions | As the agreement says |
| Contractor's say | Can respond after it takes effect | 30 days to respond | Decided after that response | Negotiated |
| New federal contracts | Excluded | Excluded | Excluded | Excluded, per its terms |
All from FAR subpart 9.4: sections 9.403, 9.405, 9.406-3, 9.406-4, 9.407-1, 9.407-2 and 9.407-4. Exceptions apply, for example up to five years for drug-free workplace violations.
Why proposed debarment catches people out
"Proposed" sounds like nothing has happened yet. It has. Under FAR 9.405(a), a contractor proposed for debarment is excluded from receiving contracts in the same breath as one debarred or suspended, and it shows in SAM.gov as an active record. A company can be proposed for debarment for months while it responds, and it is restricted throughout.
The same goes for "Proceedings Pending" in SAM.gov. In our count of 2026 exclusions, more than a quarter carried that label.
Why each one happens
- Debarment (9.406-2) can rest on a conviction or civil judgment for fraud, embezzlement, antitrust violations and similar offenses, or on a preponderance of the evidence of things like willful nonperformance, delinquent federal taxes over $10,000, or knowingly failing to disclose credible evidence of certain violations. Any other cause serious enough to affect present responsibility can also apply.
- Suspension (9.407-2) needs only suspicion on adequate evidence of largely the same causes. An indictment is adequate evidence on its own.
Conduct travels. Under FAR 9.406-5, an individual's conduct can be imputed to the contractor and the contractor's to its people, and one joint venture participant's to the others. A debarment can also extend to named affiliates. So a clean record for a company says less if its principals or sister companies have one.
What each means for a prime
FAR 9.405-2(b) treats all four alike. You may not enter into a subcontract over the threshold ($45,000 when checked, COTS items excepted) with a contractor that is debarred, suspended, proposed for debarment or voluntarily excluded, unless there is a compelling reason, and you must notify the contracting officer in writing first. See FAR 52.209-6.
A sub that is excluded after you signed is a harder question. The rule is written around entering into a subcontract, and for the government's own contracts, FAR 9.405-1 lets agencies generally continue existing contracts but limits new work, options and extensions without a compelling reason. Your position depends on your subcontract and your prime contract, so take it to counsel. What you can control is hearing about it the day it happens.
Knowing when a status changes
A sub's status can change at any time, and an exclusion can end as well as begin. Watch loads SAM.gov's exclusions daily and re-checks the suppliers a change could touch within about 15 minutes of the load. An exclusion linked by UEI or CAGE becomes a finding; a name-only resemblance is shown as a possible match for a person to decide. See how exclusion monitoring works.