Subaward & Executive-Compensation Reporting Threshold
$30,000
Also known as: FFATA subaward reporting threshold, FSRS reporting threshold
At a Glance
- Current amount
- $30,000 (first-tier subcontract awards)
- Where it is set
- FAR 52.204-10, implementing the Federal Funding Accountability and Transparency Act
- What it requires
- Reporting first-tier subcontracts in FSRS, plus executive compensation when income-threshold tests are met
- Where you report
- The Federal Funding Accountability and Transparency Subaward Reporting System (FSRS.gov)
- Applies to
- Prime contractors on contracts that themselves exceed the reporting threshold
What It Is
The subaward and executive-compensation reporting threshold is the dollar line above which a prime contractor must publicly report its first-tier subcontract awards under the Federal Funding Accountability and Transparency Act (FFATA). Implemented by the clause at FAR 52.204-10 and the procedures in FAR 4.1403, the requirement directs a prime to report, in the Federal Funding Accountability and Transparency Subaward Reporting System (FSRS), each first-tier subcontract award of $30,000 or more. The same clause requires reporting of the total compensation of the prime's — and, in some cases, the subcontractor's — five most highly compensated executives when the entity meets income-based tests (broadly, when it derived most of its revenue from federal awards above a specified dollar volume and that information is not otherwise public). The purpose is transparency: FFATA data feeds public spending databases so the flow of federal dollars, including down to subcontractors, can be tracked. The threshold matters because it defines the paperwork a prime must maintain and file, and it makes an SDVOSB's role as a subcontractor part of the public record.
What Changes at This Dollar Level
- A prime must report each first-tier subcontract award of $30,000 or more in the FSRS system.
- The prime must report the total compensation of its top five executives when the income-based tests in FAR 52.204-10 are met.
- In some cases the subcontractor must provide its own executive-compensation information to the prime for reporting.
- Subcontract awards below $30,000 are not subject to the FSRS reporting requirement.
Key Features
| Feature | What It Means |
|---|---|
| First-tier subcontract reporting | The prime reports each first-tier subcontract of $30,000 or more — the identity, amount, and description of the subaward — in FSRS. |
| Executive compensation | When income-based tests are met, the prime (and sometimes the subcontractor) must report the total compensation of its five most highly compensated executives. |
| A transparency mechanism | FFATA data feeds public federal-spending databases, so the flow of dollars down to subcontractors is publicly visible. |
| Falls on the prime | The reporting obligation sits with the prime contractor, but subcontractors must supply the information the prime needs to file. |
What It Means for an SDVOSB
For a service-disabled veteran-owned small business, this threshold shows up in two ways. As a subcontractor, your award becomes part of the public record once a prime reports it in FSRS, and the prime will ask you for the data — your unique entity identifier, and possibly executive-compensation information — so keeping your SAM.gov registration current and your entity data clean makes you an easy teaming partner rather than a reporting headache. As a prime, once you are large enough to be subcontracting work out, you inherit the reporting obligation yourself: every first-tier subcontract of $30,000 or more has to be reported, so build the FSRS filing step into your subcontract administration from the first award. Either way, the practical lesson is that accurate, up-to-date entity registration in SAM.gov is what keeps FFATA reporting from becoming friction in a teaming relationship.
Watch Out For
- Forgetting the prime carries the filing duty — but the subcontractor must supply accurate entity and, where required, executive-compensation data.
- Letting SAM.gov registration lapse — stale entity data makes FFATA reporting difficult and signals an unreliable teaming partner.
- Assuming small subcontracts are reportable — the threshold is $30,000, so smaller subawards are not reported in FSRS.
- Overlooking the executive-compensation piece, which turns on income-based tests separate from the $30,000 subaward line.
Run the Numbers
Frequently Asked
What is the FFATA subaward reporting threshold?
It is the dollar line — $30,000 — above which a prime contractor must report each first-tier subcontract award in the Federal Funding Accountability and Transparency Subaward Reporting System (FSRS). The requirement comes from the Federal Funding Accountability and Transparency Act, implemented by the clause at FAR 52.204-10 and the procedures in FAR 4.1403. The same clause requires reporting certain executive compensation when income-based tests are met.
Who has to report subcontract awards under FFATA?
The reporting obligation falls on the prime contractor, which must report each first-tier subcontract of $30,000 or more in FSRS. Subcontractors do not file the report themselves, but they must supply the prime with the information needed to file — including their unique entity identifier and, when the income-based executive-compensation tests apply, their top executives' total compensation. Keeping SAM.gov registration current is what makes this smooth.
How does FFATA reporting affect an SDVOSB subcontractor?
When an SDVOSB takes a first-tier subcontract of $30,000 or more, the prime will report that subaward in FSRS, making it part of the public spending record, and will ask the SDVOSB for the data it needs to file. The main practical impact is administrative: an SDVOSB with an accurate, up-to-date SAM.gov registration is an easy teaming partner, while stale or missing entity data creates friction for the prime's reporting.
Primary Sources
- FAR 52.204-10 — Reporting Executive Compensation and First-Tier Subcontract Awards
- FAR 4.1403 — Contract clause (subaward reporting)
- FSRS — Federal Subaward Reporting System
Plain-English reference, not legal advice. Acquisition-related dollar thresholds are periodically re-indexed for inflation and the underlying FAR sections and statutes are amended from time to time — always confirm the current figure and its exceptions against the FAR and the actual solicitation before relying on it, and consult qualified counsel for your specific situation.
Change log (1)
- LaunchedPublished the federal procurement dollar thresholds reference covering the dollar lines that shape an SDVOSB set-aside — the micro-purchase threshold (FAR 2.101), the simplified acquisition threshold and the automatic small-business reserve (FAR 2.101 / 19.203), the commercial simplified-procedures ceiling (FAR 13.500), the SDVOSB sole-source ceiling (FAR 19.1406), the subcontracting-plan threshold (FAR 52.219-9), the certified cost or pricing data / TINA threshold (FAR 15.403-4), the Cost Accounting Standards threshold (48 CFR 9903.201-1), the Service Contract Labor Standards (41 U.S.C. § 6702) and Davis-Bacon (40 U.S.C. § 3142) labor thresholds, and the FFATA subaward reporting threshold (FAR 52.204-10) — each with an at-a-glance quick-facts card showing the current dollar amount, a what-changes-at-the-line list, a key-features table, an SDVOSB-specific angle, watch-outs, FAQPage, Article, Dataset, and BreadcrumbList structured data, primary-source citations, and cross-links into the glossary, regulation explainers, clauses, how-to guides, FAQ, and the size-standard, set-aside eligibility, subcontracting, and price-to-win calculators.