Independent, not SAM.gov

The October 2026 federal shutdown, and your contracts

Updated 6 October 2026

ZeroGov covers US federal contracting. We are not SAM.gov, not a help desk, and not a paid service. The page below is a working map of the 1 October 2026 funding lapse and what it does to obligations, options, your pay, and your SAM.gov record.

What this page is not

It is not the SAM.gov help desk. It is not GSA, OPM, or the Department of the Treasury. It is not a paid service, and we do not see or touch your entity record. Anything that looks like an urgent charge for “expedited renewal” is a scam; SAM.gov is free and so is renewal. We are independent, and our only job here is to walk small vendors and new entrants through what the 1 October 2026 funding lapse changes and what it does not.

Where the government actually is right now

Funding for fiscal year 2027 lapsed at 12:01 am eastern on 1 October 2026, and continuing resolutions had not cleared. The Antideficiency Act takes effect from that moment. OMB’s contingency plan, last refreshed 30 September 2026, estimates around 41 percent of the federal workforce is furloughed, with the rest retained because their work is tied to funded programs, safety, or the protection of life and property. The exact mix is uneven: USDA’s SNAP and WIC operations are funded through mandatory accounts, so FNS work continues; the IRS is in a partial posture with seasonal shutdown rules; and most discretionary procurement offices are open only to close out what was already on the books.

The shutdown follows the pattern of the January 2019 lapse, the December 2018 lapse, and the 35 day event in 2018 to 2019. Appropriations, not agencies, drive the cycle. The agencies are still there, the staff still exist, and the records are still in SAM.gov, they just do less, and a lot of the things you are used to seeing go live again pause for the duration.

What still moves, and what does not

Think of the lapse in two lanes: the old money lane and the new money lane.

The old money lane covers obligations made before 12:01 am on 1 October 2026. Discretionary contracts that were awarded and obligated in fiscal year 2026 still pay. Performance continues, invoices are processed, options are exercised, and the contracting officer keeps the file moving. Mandatory funded work, Medicare, Social Security administration, federal retirement, SNAP, defence health, and the bulk of DoD operations carried by prior year funds, is mostly unaffected by the lapse in practical terms. The Antideficiency Act does not void obligations that were valid when made.

The new money lane covers obligations that would be made from FY 2027 appropriations. Those stop. New awards pause, new task orders against existing IDIQs are reviewed, and any modification that crosses the threshold of an FY 2026 obligation is treated carefully. Contracting officers can keep doing administrative work, file the contract into the file, and process options on contracts funded before the lapse, but they cannot legally create a new obligation against FY 2027 money. Expect a backlog when the lapse ends, which is exactly what happened in January 2019 and in the 21 day lapse of 1996.

Your SAM.gov record during a lapse

SAM.gov is operated by GSA under a working capital fund, which means the system stays online through a lapse. That said, the back office does not. Entity validation runs through an external partner. New registrations, edits that change your legal business name, TIN, or address, and CAGE updates are queued. They will move again when the staff returns; the clock for the 60 day renewal window still runs, and an expired record still becomes ineligible for award. The “Active” status you see in the entity record reflects the validity of the data, not the funding state of the United States government.

If you are about to receive an award, the contracting officer will pull your entity record. Make sure your record is in a clean Active state now, because the validation queue will not be the place to discover a mismatch in the middle of a lapse. If you have an open help desk ticket, do not expect a response this week. The Federal Service Desk is a paid service with surge pricing, and during the 2018 to 2019 lapse the median ticket response time stretched to 11 business days at one point. We strongly recommend you avoid paying any third party to “push” a ticket; SAM.gov registration is free, and renewal is also free. Anyone charging you to talk to the help desk is selling something that does not exist.

Pay, invoices, and the people you sell to

Payments from the federal government do not stop on the day of the lapse. Treasury has prior year funds and continuing authority to pay obligations that were validly incurred, and the Prompt Payment Act clock is still running. In practice, you may see payment times stretch, especially for civilian agencies that furloughed most of their financial workforce. DoD and the defence health agencies, which are funded through different mechanisms, generally keep paying on schedule.

On the contractor side, expect the contracting officer to be reachable but slow. The contracting officer representative (COR) is often a programme office employee, and programme offices have a higher furlough rate than the contracting office itself. Expect emails to sit in inboxes for two or three days. Treat the people you sell to with patience, and keep your own records tight: every delivery ticket, every acceptance signature, every invoice number. When the lapse ends and the backlog clears, those records are the difference between being paid in seven days and being paid in seventy.

Options, modifications, and the option exercise problem

This is the part that surprises people every time. An option in a federal contract is a unilateral right of the government, and the funding for the option is tied to the fiscal year in which the option period begins. If your contract has a 30 September 2027 option start and FY 2027 appropriations are not in place, the government cannot lawfully exercise the option on time. The agency is not committing breach. It is also not guaranteeing an exercise on the day the lapse ends.

What you can do: confirm in writing, before the option date, that you are ready, willing, and able to perform. Ask the contracting officer in advance for a written indication of intent. If the option is for a service that is required by statute or necessary to protect life and property, the agency can use a short term extension and fund it from prior year money, but the paperwork is heavier and the decision is slower. Plan for a 30 to 60 day extension of performance under your current period if the lapse runs that long.

Set asides, small business goals, and shutdown math

Set aside rules do not pause. A competition set aside for 8(a), HUBZone, WOSB, veteran owned, or service disabled veteran owned small business remains set aside, even if no awards are flowing. The small business goaling that agencies report to SBA, the 23 percent prime contracting goal and the 5 percent WOSB goal among others, is calculated on obligations, and a longer lapse cuts into the numerator. Agencies that are running behind on goals cannot use the lapse to “reset” their targets, but they can argue to SBA that a delayed year should be excluded from the average, the same way the 2013 and 2018 to 2019 lapses were handled in the goaling scorecards.

If you are counting on a set aside award, expect the date of award to slip. A clean, Active SAM.gov record, an up to date CAGE code, and accurate representations and certifications put you at the front of the line when the backlog clears. If your NAICS code is wrong, the agency will reject the award and you will lose the slot. The time to fix that record is now, not the day the government reopens.

What you should do this week

Five concrete moves:

First, log into SAM.gov and confirm that your registration status reads Active and that your CAGE code and NAICS code are correct. If your record is in the 60 day renewal window, renew it today. If you are an Entity Administrator and the original administrator left, follow the recovery steps we have written, because the FSD will not answer that call during a lapse.

Second, check your inbox for any 90 day, 60 day, or 30 day option exercise notice. Reply in writing that you are ready. Save the email. If the lapse runs past the option date, ask the contracting officer for a written non exercise notice so you can plan workforce and subcontractor commitments.

Third, delay any new solicitation response that would be evaluated during the lapse if you can. If you cannot delay, submit on time, and put a cover note in the file confirming that pricing was based on the assumption of timely government interaction. If the agency’s silence extends past the date of award, file a size or set aside protest only after you have spoken to your representative; the agency cannot make a duty to inquire decision in the dark.

Fourth, do not pay anyone to “expedite” your SAM.gov work. The system is free. The renew is also free. The banking screen is not a paid product, and no third party can talk to the FSD on your behalf. Anyone who asks for a credit card is running a known SAM.gov scam.

Fifth, keep delivering on existing obligations. Performance under a contract that was validly awarded in FY 2026 is not affected. The contracting officer needs your delivery tickets, your invoices, and your acceptances on file, so that when the lapse ends, you are at the front of the queue and not chasing a missing receipt.

How long will this last

Nobody knows. The 2018 to 2019 lapse ran 35 days and was the longest in modern history. The 1995 to 1996 lapse ran 21 days. The 2013 lapse ran 16 days. Most lapses resolve in under two weeks once political pressure builds. The appropriations calendar for FY 2027 is unusual, with a full year bill and several supplementals pending. Plan for 14 days, hope for fewer, and be ready for 30. The longer the lapse runs, the more the option exercise calendar slips, and the more the award backlog grows at agencies like DHS, State, and the smaller civilian bureaus.

Where to look, and who to call

OMB’s contingency plan, refreshed on 30 September 2026, lists which agencies are open and which are not, and at what staffing level. The GAO bid protest clock is interesting reading during a lapse, and we will cover that separately. SBA’s size protests and the Office of Hearings and Appeals continue to function because they are funded through different mechanisms, and you can still file a size protest. The opportunity feeds on SAM.gov continue to publish, but the response dates slip.

If you are a new entrant and the shutdown is the reason you cannot complete your first registration, the answer is patience. Do not pay anyone to push your application, do not pay anyone to “expedite” your CAGE, and do not hand over your banking screen credentials. The registration is free, it is also legitimate, and it will validate when the staff returns.

A short note on scams during a lapse

Scammers use shutdowns. The SAM.gov scam playbook is well known: an email pretending to be the Federal Service Desk asks for a “reactivation fee” or a “validation fee”, or a robocaller claims your CAGE is about to be deactivated. None of this is real. SAM.gov is free, renewal is free, and the FSD will never ask for payment over the phone. The entity record does not deactivate during a lapse. If you are contacted, hang up, do not click the link, and report the message to the FTC at reportfraud.ftc.gov. Then go to our checklist and confirm the record yourself.

Independent information, not legal advice. Confirm status and rules on sam.gov and the current FAR text.