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FAPIIS and integrity records: what they are and how to watch them

FAPIIS held information about a contractor's integrity and performance: terminations for default or cause, non-responsibility determinations and similar records, plus the proceedings a contractor reports about itself. GSA has retired the system, but not the records. Contracting officers still review them before awards, and primes should look at them for their subs.

Checked against the official sources on October 31, 2026. General information, not legal advice.

FAPIIS or integrity records?

They are the same information under a new name. The Part 9 proposed rule of September 18, 2026 says GSA retired FAPIIS as part of its systems modernization, that the records are now read in SAM.gov and reported in CPARS.gov, and it replaces the term "FAPIIS" with "integrity records". That rule isn't final and the FAR as codified still says FAPIIS, so you will see both names for a while.

What's in them

  • Responsibility records entered by agencies: for example terminations for default or cause, non-responsibility determinations and administrative agreements
  • Proceedings the contractor reported itself under FAR 52.209-7: criminal, civil and administrative proceedings connected with federal awards over the last five years

These records are shown with the entity's record in SAM.gov. Under FAR 9.104-6, contracting officers review them before awards above the simplified acquisition threshold. A record isn't an exclusion; it is information a responsibility decision takes into account. The proposed text also says records posted by the government go public after 14 calendar days, so a contractor has a short window to see a posting first.

Why a prime watches it for subs

A new termination for default or a newly reported proceeding is the kind of thing you want to know before you renew or expand a subcontract, not after a contracting officer asks about it.

The FAR makes responsibility a chain. A prospective prime is responsible for determining the responsibility of its prospective subs, and the proposed text keeps the point that those determinations can affect the government's view of the prime. A record doesn't bar a sub, but it should prompt a question, and your file should show the answer.

What to do when you find a record

  • Read what it is: a termination for default weighs differently from an administrative agreement, and a reported proceeding may have closed in the company's favor
  • Check the date and whether it relates to the kind of work you are buying
  • Ask the sub what happened and what changed since
  • Record your decision and the reason, so the next person doesn't have to start over

How Watch does it

Watch asks the SAM.gov Entity API for the registrations its customers watch, within SAM.gov's daily call allowance, and turns each responsibility record and reported proceeding into a finding with its date. A new supplier's answer can take a day or more to arrive; until it does, Watch shows it as unknown, never as "none".

Proceedings are shown by their named fields (date, type, disposition, instrument); free-text descriptions, which can name people, aren't kept. A watch can be told to alert on these ("Watch UEI … for FAPIIS records, critical").

Try it on your own suppliers

The first 5 suppliers are included. No card to start. Paste UEIs, upload a list or type one sentence.

Questions

Is a FAPIIS record the same as an exclusion?
No. An exclusion bars most federal awards. A FAPIIS record is information about integrity and performance that a responsibility decision takes into account.
Where is FAPIIS now?
GSA retired FAPIIS. The records are now called integrity records in the Part 9 proposed rule of September 18, 2026: they are read in SAM.gov, with the entity's record, and reported in CPARS.gov.
Do I have to check integrity records for subcontractors?
The rule requiring review is written for contracting officers. For a prime it is prudent rather than a stated clause duty: primes are responsible for determining their subs' responsibility, and a record is information that bears on it.
How fresh is Watch's FAPIIS data?
Watch asks the SAM.gov Entity API within its daily allowance, so a new supplier's answer can take a day or more. Until then it is shown as unknown, not as none, and every answer carries the day it was fetched.

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