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Pre-award subcontractor screening checklist

Eight checks, in the order that saves the most rework. Which ones your award needs depends on the prime contract, the subcontract's value and what the sub will touch, so treat this as the list to start from and read the clauses in your own contract.

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

The checklist

Pre-award subcontractor screening checklist
CheckWhyWhere to lookKeep
1. The right companyEvery later check is only as good as this oneUEI and CAGE codeThe identifier, and how you matched it
2. SAM.gov statusTells you what the public record can say about the sub, and any expirySAM.gov entity recordStatus and expiry date, with the date you read them
3. ExclusionsFAR 52.209-6SAM.gov exclusionsThe search, its date, and every result you decided on
4. Written disclosure52.209-6(c), for the sub and its principalsThe subThe signed disclosure
5. Integrity recordsResponsibility: yours, and the agency's view of yoursSAM.gov integrity recordsAny record, and what you did about it
6. Sanctions and export listsOFAC and export rules, whatever the contract saysConsolidated Screening ListEach possible match and the decision on it
7. Section 889The telecom prohibitionThe sub, after a reasonable inquiryThe sub's signed answer
8. Cybersecurity statusCMMC flow-downThe sub, for DoD work with FCI or CUIThe sub's level, status date and SPRS score

For grant money the rules differ: see 2 CFR 180 and 200 for subrecipients.

Which checks depend on the award

  • Value. The 52.209-6 prohibition, disclosure and flow-down apply to subcontracts over the threshold in FAR 9.405-2(b), $45,000 when this guide was checked. Many primes screen below it anyway, because the check costs little and an exclusion is a poor thing to find later.
  • What is being bought. Subcontracts for commercially available off-the-shelf items are outside 52.209-6. Section 889 has no such carve-out: its clause goes in all subcontracts, commercial ones included.
  • What the sub will touch. CMMC flow-down depends on whether the sub will process, store or transmit FCI or CUI.
  • Where the money comes from. A contract, a grant and a commercial sale each bring their own rules. The prime contract decides, not a checklist.

When to run it

Run it when you onboard a sub, and again close to each award. 52.209-6 asks for the disclosure "as of the time of award", so a check from onboarding isn't the same as a check before award. In our count, exclusions took effect in every month of 2026, in uneven batches, so a quiet month says little about the next one.

Options and modifications deserve a look too: new work is a natural moment to check again, even when no new subcontract is being signed.

What the file should show

A contractor's compliance with 52.209-6 is reviewed during Contractor Purchasing System Reviews (FAR 9.405-2(c)), so someone may ask for this years later. A reviewer wants to see, for each sub:

  • Which registration you checked, and why you knew it was the right one
  • The date of each check, and the data date of the list behind it
  • What came back, including possible matches, and who decided them
  • What you did about anything you found

How Watch helps

Watch runs checks 1 to 3, 5 and 6 from public records once you confirm a supplier's registration, and collects 7 and 8 from the supplier through its portal, with a Section 889 questionnaire and a CUI handling and CMMC status questionnaire. Type a deadline into a watch ("before the Nov 14 award") and the day before it re-checks each confirmed supplier and freezes a dated snapshot.

Check 4 stays yours: Watch's sanctions declaration isn't worded as the 52.209-6 disclosure, so use your own form and keep the signed copy on the supplier. Per supplier, the record comes out as a PDF evidence package.

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

What should I check before awarding a subcontract?
Confirm the right company by UEI or CAGE, read its SAM.gov status, search exclusions, get its written disclosure, review integrity records, screen the sanctions and export lists, and collect Section 889 and, for DoD work with FCI or CUI, CMMC status. Your prime contract decides which apply.
How often should subcontractors be screened?
At onboarding, close to each award, and on a schedule in between. FAR 52.209-6 speaks of the time of subcontract award, and exclusions can take effect on any day.
Do I need to screen subcontracts below $45,000?
FAR 52.209-6 applies above the FAR 9.405-2(b) threshold, $45,000 when this guide was checked, but other rules have no such threshold: Section 889 goes in all subcontracts, and sanctions rules apply whatever the value. Many primes screen every sub.
Who reviews a prime's subcontractor screening?
Compliance with FAR 52.209-6 is reviewed during Contractor Purchasing System Reviews, under FAR 9.405-2(c). Your contract or a customer may add its own.

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