FAR 52.204-25 — Prohibition on Certain Telecommunications and Video Surveillance Services or Equipment

This clause implements the Section 889 prohibition on covered telecommunications equipment and services. It applies to your entire operation, not just what you deliver to the government.

Clause
FAR 52.204-25
Applies to
All contracts
Flows down to subs
Yes
Primary risk
Supply chain violations

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 may not provide or use covered equipment or services from named entities as a substantial or essential component of any system. Discovery of covered items requires prompt reporting to the contracting officer with defined details and mitigation.

How to comply in practice

Inventory your network gear, cameras, and telecom services, obtain supplier attestations, and add contract language requiring subcontractors to certify compliance. Document the review so your representation in SAM is defensible.

Common mistakes

Small firms certify compliance without ever checking their own camera systems or downstream suppliers. A false representation is a serious matter even when unintentional.

FAQ

Does it cover equipment I use internally?

Yes. Part B of Section 889 restricts use of covered equipment or services in your operations.

Who are the covered entities?

Named Chinese telecom and video surveillance manufacturers and their affiliates identified in statute.

What if I find covered equipment?

Report to the contracting officer promptly with the required details and a mitigation plan.

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