E-Verify on federal contracts: what bidders and subs must do
Win a federal job and the paperwork doesn't stop at bonds and insurance. If the contract includes the E-Verify clause, your company has hard deadlines that start at award.
- The clause goes in solicitations and contracts over $150,000, except those under 120 days, those performed only outside the U.S., and certain COTS-only buys.
- If you're not enrolled at award, you must enroll as a Federal Contractor within 30 calendar days.
- New hires working in the U.S. must be run through E-Verify within 3 business days of hire, once the start-up window applies.
- The clause flows down to subcontracts for services or construction over $3,500 with work performed in the U.S.
When the clause applies
FAR 22.1803, E-Verify contract clause prescription says to insert FAR 52.222-54 in "all solicitations and contracts that exceed $150,000," except those performed only outside the United States, those "for a period of performance of less than 120 days," and those only for COTS items and related services.
Deadlines if you aren't enrolled yet
Under FAR 52.222-54, Employment Eligibility Verification, a contractor not enrolled at award must:
- Enroll as a Federal Contractor in E-Verify "within 30 calendar days of contract award."
- Verify all new hires: within 90 calendar days of enrollment, start verifying all new hires working in the U.S., "whether or not assigned to the contract, within 3 business days after the date of hire."
- Verify employees assigned to the contract: within 90 calendar days after enrollment or within 30 calendar days of the employee's assignment, whichever is later.
Contractors may instead choose to verify all existing employees hired after November 6, 1986, within 180 calendar days.
Flow-down to subs
The clause must be included in each subcontract that is for services or construction, "has a value of more than $3,500," and includes work performed in the United States. If you're a sub on a federal job, expect to see it in your contract.
Bid-stage tips
- Search the solicitation for 52.222-54 before bid day.
- Budget admin time for enrollment and verification if you've never used E-Verify.
- Ask your subs whether they're enrolled, since the clause flows down to them too.
Related: SAM.gov registration and Davis-Bacon prevailing wages.
General information, not legal advice. Thresholds change; always read the clause in your solicitation. Sources: FAR 22.1803, E-Verify contract clause prescription; FAR 52.222-54, Employment Eligibility Verification.
Published October 31, 2026. We do not use affiliate links on this page; see our Affiliate Disclosure.