FAR 52.204-10 — Reporting Executive Compensation and First-Tier Subcontract Awards
This clause implements the Federal Funding Accountability and Transparency Act, requiring contractors to report first-tier subcontract awards and, in some cases, executive compensation through FSRS.gov. It is a transparency reporting obligation, not a substantive performance requirement.
- Clause
- FAR 52.204-10
- Applies to
- Contracts of $30,000 or more
- Flows down to subs
- Yes for first-tier subcontracts meeting the threshold
- Primary risk
- Missed FFATA reporting deadlines
Key takeaways
- Read the clause as incorporated in your contract — tailoring and alternates change obligations.
- Flowdown obligations are your responsibility; a noncompliant subcontractor is your problem.
- Document compliance contemporaneously; after-the-fact reconstruction rarely satisfies auditors.
- When a clause is unclear, ask the contracting officer in writing before award, not after.
What the clause requires
You must report the name, amount, and location of each first-tier subcontract award of $30,000 or more within the required timeframe after award, and disclose the names and total compensation of your five most highly compensated executives if your revenue and compensation criteria trigger disclosure.
How to comply in practice
Assign one administrative owner to file FSRS reports on a fixed schedule after each subcontract award, and keep a running log of qualifying subcontracts so nothing is missed near year-end reporting cycles.
Common mistakes
The common failure is simply forgetting the filing exists because it sits outside normal invoicing and project workflows. Missed reports surface during contract closeout reviews and CPARS write-ups.
FAQ
What is FSRS?
The FFATA Subaward Reporting System, where first-tier subcontract awards meeting the threshold are reported.
Does every contractor report executive compensation?
Only those meeting the revenue and public-availability criteria in the clause; most small contractors are exempt from that portion.
When is the report due?
By the end of the month following the month of the subcontract award, per the clause's reporting cycle.
Draft a compliant response for $2
RFP Scribe builds your compliance matrix and first draft from the solicitation and your Company Brain.
Get startedServices that help with this
Buy just the piece you need — most start at a few dollars, no subscription required.
Compliance & Readability Scan
$2Verify every FAR requirement is addressed in your proposal.
Buy NowRFP Plain-English Summary
$3Translate dense solicitations with FAR references into actionable checklists.
Buy NowContract Modification Writer
$10Generate compliant modification requests with proper FAR citations.
Buy Now