Corporate Restructuring and Your CAGE Code: What Changes and What Stays the Same

Corporate changes happen — companies merge, rebrand, spin off divisions, or restructure for tax or liability reasons. In the commercial world, most of these changes are handled through legal filings and updated bank accounts. In federal contracting, corporate changes intersect with CAGE codes, SAM.gov registrations, and existing contract obligations in ways that require careful advance planning.

Name Changes

If your company changes its legal name (not just a DBA), you must update your SAM.gov entity registration to reflect the new legal name. The underlying CAGE code remains the same — CAGE codes follow the entity, not the name. However, the name in your CAGE code record will be updated in DLA's system to reflect the new legal name. You will also need to update all existing contracts with a contract modification, and potentially a novation agreement if there is an assignment of contract obligations.

Address Changes

An address change is particularly significant if you hold HUBZone certification. Moving your principal office out of a HUBZone-designated area will result in immediate loss of HUBZone certification status. Update your SAM.gov registration promptly when you change addresses, and notify your contracting officers. The updated address will be reflected in your CAGE code record within a few business days of SAM.gov processing the change.

Acquisitions and Mergers

When one company acquires another, the acquiring company's CAGE code typically continues. The acquired company's CAGE code may be retained as a separate entity or deactivated, depending on whether the acquired entity continues as a legal subsidiary or is fully merged. This distinction matters for past performance — CPARS records tied to the acquired company's CAGE code belong to that entity and may or may not be citable depending on how the acquisition is structured.

The Novation Agreement

Under FAR Subpart 42.12, when a contractor transfers all its assets or a division (including government contracts) to a successor, a novation agreement is required. The novation replaces the original contractor with the successor on existing contracts and requires government approval. The successor will typically operate under its own CAGE code, and all affected contract records will be updated to reflect the successor's CAGE code.

Small Business Size Recertification

Certain contract events — including novations and long-term contract option exercises — trigger size recertification requirements. If the successor is larger than the small business size standard, a previously set-aside contract may no longer be eligible for further options under the small business set-aside. Consult with your contracting officer and SBA advisor before completing a merger or acquisition that affects a size-sensitive contract.

Keeping Your CAGE Code Record Accurate

Throughout any corporate change, keep your CAGE code record accurate by updating SAM.gov promptly and proactively notifying your contracting officers. Verify the updated record using our CAGE Code Decoder to confirm that the changes are reflected accurately. A CAGE code record that lags behind your actual corporate structure creates compliance exposure across all your active contracts.