Reps and Certs: The Hidden Risks in Federal Contracting Compliance

Article

October 8, 2025

When U.S. government agencies evaluate companies for federal contracts, they rely heavily on representations and certifications (commonly known as reps and certs). These attestations, submitted annually through the System for Award Management (SAM), cover everything from small-business status to foreign ownership disclosures. While they serve as an important compliance checkpoint, reps and certs alone are not enough to protect critical supply chains.

Limitations of Reps and Certs in Supply Chain Risk Management

Reps and certs provide a baseline of information, but they suffer from several key vulnerabilities:

Vague Language
Ambiguity in regulatory definitions—such as what constitutes “foreign government control”—creates opportunities for incomplete or misleading disclosures. For example, a U.S. subsidiary of a foreign state-owned enterprise might not report its ultimate ownership, exposing the government to hidden foreign ownership, control, or influence (FOCI) risk.
Potential for Intentional Dishonesty
Adversarial nations seek to infiltrate supply chains to gain access to sensitive technology, disrupt materials flow, or introduce compromised components. If procurement officers rely solely on self-reported attestations, they risk overlooking deliberately concealed ownership or control.
Unintentional Errors
Reps and certs are often completed by individuals without full visibility into their company’s supply chain, ownership, or compliance posture. Even well-intentioned attestations can inadvertently omit critical risk factors.

The Path Forward: How to Strengthen Supply Chain Risk Management Beyond Reps and Certs

Overreliance on reps and certs creates blind spots that adversarial entities can exploit. If discrepancies or omissions surface after a contract is awarded, it may be too late to safeguard sensitive supply chains, government systems, or national security interests.

To secure federal procurement, contracting officers need to:

Validate attestations with independent intelligence sources
Cross-reference disclosures with corporate ownership data
Continuously monitor supply chain risk factors

By integrating multiple sources of truth, the government can move beyond reliance on self-attestations and gain the comprehensive visibility needed to protect critical supply chains.

How Exiger Can Help: From Compliance to Confidence

At Exiger, we go beyond compliance to deliver actionable intelligence that ensures federal procurement is not just compliant — but resilient and secure.

Deeper Ownership Transparency: Our AI-powered due diligence platforms uncover ultimate beneficial ownership, layered corporate structures, and hidden foreign government influence that reps and certs may miss.
Continuous Risk Monitoring: Instead of static, annual attestations, Exiger enables real-time monitoring of vendors and supply chains to catch changes in ownership, sanctions, and high-risk exposure.
Augmented Procurement Decisions: We empower contracting officers with the intelligence needed to verify reps and certs against independent data sources, reducing the risk of intentional or unintentional misrepresentation.

By pairing reps and certs with Exiger’s trusted supply chain intelligence solutions, agencies can safeguard national security, mitigate FOCI risk, and maintain the integrity of federal procurement programs.

Discover how Exiger transforms static attestations into actionable insights for federal procurement.