What Is FFATA? Requirements, Reporting, and Penalties

FFATA is the Federal Funding Accountability and Transparency Act, a 2006 law (Public Law 109-282) that requires the federal government to publish detailed data about every significant contract, grant, and loan it awards, and that requires organizations receiving federal funds to report the subawards they pass down. The public-facing result is USAspending.gov, where anyone can trace tax dollars from a congressional appropriation to the business or nonprofit that ultimately spent them. If you receive federal money or work with someone who does, FFATA is also a set of filing obligations you have to meet.¹

What the Law Does

FFATA directed the government to build a centralized, publicly accessible website displaying federal spending data. It covers contracts, grants, loans, cooperative agreements, and other forms of financial assistance with an obligation value of $25,000 or more. The law made transparency a permanent statutory requirement rather than a policy choice, so the window into the federal ledger stays open across administrations.²

How the DATA Act Expanded FFATA

In 2014, Congress passed the Digital Accountability and Transparency Act (Public Law 113-101), commonly called the DATA Act. It broadened FFATA’s original framework by adding direct agency spending, linking contract, grant, and loan data to specific program activities and budget categories, and requiring government-wide data standards so information from different agencies could be compared.³ The DATA Act also required published information to be available in machine-readable, open formats.⁴ Today’s reporting system reflects both laws.

Who Has to Report Under FFATA

The subaward reporting burden falls on the prime recipient, the organization that receives funding directly from a federal agency. When a prime recipient passes money to a sub-recipient through a subcontract or subgrant, the prime recipient files the FFATA report. The sub-recipient does not.

The reporting threshold is $30,000. Any single action that obligates $30,000 or more in federal funds to a sub-recipient triggers a report by the prime recipient.⁵ That is separate from the $25,000 minimum for awards displayed on USAspending.gov. Grants and contracts are both covered, so private contractors face the same rules as nonprofits and universities.

Who Is Exempt

Individuals who receive a federal award as a natural person, meaning the award has nothing to do with a business or nonprofit they operate, are fully exempt. Organizations with gross income under $300,000 in the previous tax year are exempt from both subaward reporting and executive compensation disclosure.⁶ The Office of Management and Budget can also grant exceptions for entire classes of awards or recipients when the statute allows.

Executive Compensation Disclosure

A separate reporting layer applies to organizations that lean heavily on federal revenue. If your entity received 80 percent or more of its annual gross revenue from federal contracts, subcontracts, grants, and cooperative agreements in the preceding fiscal year, and that federal revenue totaled $25,000,000 or more, you must disclose the names and total compensation of your five highest-paid executives.⁵ Both conditions must be true. Prime recipients also report the same executive compensation data for first-tier sub-recipients that meet both thresholds.⁶

One carve-out: if the executive compensation information is already publicly available through SEC filings (periodic reports under Sections 13(a) or 15(d) of the Securities Exchange Act) or through IRS filings under Section 6104 of the Internal Revenue Code, you do not need to report it separately through FFATA.

What You Have to Report

Before filing anything, your organization needs an active registration on SAM.gov, the System for Award Management. SAM.gov assigns a Unique Entity Identifier (UEI), the alphanumeric code that replaced the old DUNS number.⁷ Renew your SAM.gov registration every 365 days. A lapse can block new awards and interfere with reporting.

For each reportable subaward, the prime recipient provides:

Sub-recipient legal name, physical address, and UEI
Location of performance, including the congressional district
Dollar amount of the subaward and the date of obligation
The Catalog of Federal Domestic Assistance (CFDA) number or other program identifier tying the subaward to its parent federal program
Names and total compensation of the sub-recipient’s five highest-paid executives, if the revenue thresholds above are met

Discrepancies between your subaward report and SAM.gov data can trigger validation errors and may draw scrutiny from the awarding agency or federal auditors.

Where to File

Subaward reports used to be filed through FSRS.gov, the FFATA Subaward Reporting System. That site was retired on March 8, 2025, and all subaward reporting now lives on SAM.gov.⁸ If you had an FSRS.gov account, you can sign in to SAM.gov with your legacy FSRS credentials, verify your entity name and UEI, and confirm your reporting role in your SAM.gov Workspace under “My Roles.”

New users request the Data Entry role through their SAM.gov Workspace and should note in the request that they need subaward reporting permissions. The workflow itself is straightforward: select the prime award, enter sub-recipient data for each reportable subaward, review, and submit. The confirmation is your receipt.

When Reports Are Due

FFATA runs on a rolling monthly deadline. Report each subaward by the end of the month following the month in which the obligation was made. A subaward issued anywhere in June is due by July 31. One issued on October 1 or October 31 is due by November 30.⁹ The same cycle applies to executive compensation data for sub-recipients.⁵

Reporting is not a one-time event. If the amount of a subaward changes during the life of the project, whether up or down, update the report on the same monthly cycle.

How Long to Keep Records

Federal regulations require you to keep records related to a federal award for at least three years from the date you submit your final financial report. For awards renewed quarterly or annually, the three-year clock starts from the most recent quarterly or annual financial report.¹⁰ Save your subaward report confirmations, the underlying data used to compile each report, and any correspondence with sub-recipients about the information they supplied.

What Happens If You Do Not Comply

Missed FFATA reports carry real consequences. Under 2 CFR 200.339, federal agencies have a graduated set of remedies:

Withholding payments until corrective action is taken
Disallowing costs tied to the noncompliant activity
Suspending or terminating the award
Initiating government-wide debarment, which typically bars you from federal contracting and financial assistance for up to three years
Withholding future funding for the project or program

Reporting history also shows up in performance records. Under federal acquisition rules, compliance with database reporting requirements, including FFATA, is a factor in contractor performance evaluations recorded in the Contractor Performance Assessment Reporting System (CPARS).¹¹ A poor CPARS rating follows you into future competitions. Grant-making agencies review reporting compliance when deciding whether to renew or extend funding.

1
USAspending.gov. About
2
Congress.gov. Public Law 109-282 – Federal Funding Accountability and Transparency Act of 2006
3
Treasury Financial Experience. About the Data Transparency Program
4
Congress.gov. Public Law 113-101 – Digital Accountability and Transparency Act of 2014
5
eCFR. 2 CFR Part 170 – Reporting Subaward and Executive Compensation Information
6
Health Resources and Services Administration. Requirements for Federal Funding Accountability and Transparency Act Implementation
7
SAM.gov. Entity Registration
8
SAM.gov. Subaward Reporting in SAM
9
U.S. Election Assistance Commission. FFATA
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eCFR. 2 CFR 200.334 – Record Retention Requirements
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Acquisition.GOV. FAR Subpart 42.15 – Contractor Performance Information