The Online Representations and Certifications Application (ORCA) was a secure, web-based system developed by the U.S. federal government to centralize and streamline the submission of contractor representations and certifications (reps & certs) — a critical component of federal procurement. Prior to its development, contractors were required to submit these documents individually with each offer, creating redundancy and administrative burden for both vendors and contracting officers.
Launched in 2004, ORCA quickly became a standard requirement for federal contractors, allowing them to submit and maintain their certifications in one centralized location. Today, ORCA no longer exists as a standalone platform — it has been fully integrated into the System for Award Management (SAM), which now serves as the official system of record for federal contractor registration, certification, and compliance.
While the name ORCA is largely historical, it remains relevant in procurement terminology and in legacy documentation. Understanding ORCA and its role in the evolution of federal acquisition systems is important for grasping how modern registration and compliance functions operate within SAM.gov.
Purpose of ORCA in Federal Contracting
Representations and certifications are standardized legal statements that a contractor must make regarding their business status, ethics, compliance with federal laws, and eligibility to receive federal awards. These statements are required under the Federal Acquisition Regulation (FAR) and are reviewed by contracting officers during the source selection and award process.
ORCA was developed to:
- Eliminate redundancy in submitting reps and certs with every offer
- Ensure accuracy and timeliness of contractor self-certifications
- Provide contracting officers with real-time access to compliance status
- Support transparency and risk mitigation in federal contracting
By enabling contractors to submit their reps and certs once annually — and update them as needed — ORCA improved efficiency and reduced the risk of inconsistent or outdated information being used in source selection.
Common Certifications Submitted via ORCA
Contractors using ORCA (and now SAM) submit a wide range of certifications required under FAR Part 52 and other authorities. These may include statements on:
- Business size (e.g., small business, woman-owned, veteran-owned)
- Compliance with the Buy American Act
- Registration in the System for Award Management (SAM)
- Absence of debarment, suspension, or tax delinquency
- Environmental compliance and clean air/water acts
- Foreign ownership or control, when applicable
- Anti-kickback and anti-corruption laws
These representations help contracting officers assess a company’s eligibility and risk profile before making an award. They also provide legally binding affirmations from the contractor, which may be subject to audit or enforcement action in cases of misrepresentation.
Transition from ORCA to SAM.gov
In July 2012, the General Services Administration launched SAM.gov, a consolidated platform that merged multiple legacy systems into a single portal for federal procurement data and contractor registration. These systems included:
- CCR (Central Contractor Registration)
- FedReg (Federal Agency Registration)
- ORCA (Online Representations and Certifications Application)
- EPLS (Excluded Parties List System)
As part of this transition, ORCA was decommissioned and its functionality fully integrated into SAM’s Representations and Certifications section, commonly referred to as “Reps & Certs” in SAM.
Contractors now complete their reps and certs during initial registration in SAM.gov and are required to update them at least annually — or whenever a material change occurs. Failure to do so may result in inactivation of the SAM registration or disqualification from award consideration.
Current Functionality in SAM.gov
In the current SAM environment, the legacy functions of ORCA are embedded within a contractor’s entity registration. The process includes:
- Filling out Representations and Certifications online during registration
- Answering FAR- and DFARS-based questions covering socioeconomic status, regulatory compliance, and ownership
- Certifying to the accuracy of information, under penalty of perjury
Once submitted, the Reps & Certs section becomes visible to all federal contracting officers and is used during proposal evaluation. Updates can be made by logging into the SAM account and modifying the entity record.
SAM.gov also maintains a public record of registered entities and their certification status, supporting transparency and due diligence in the contracting process.
Importance for GSA Schedule Contractors
For contractors pursuing a GSA Multiple Award Schedule (MAS) contract, accurate and up-to-date Reps & Certs (formerly filed in ORCA) are mandatory. GSA contracting officers review this section during the offer evaluation process to ensure:
- The offeror is not suspended or debarred
- The entity is properly registered in SAM.gov
- Socioeconomic claims (e.g., small business, HUBZone, SDVOSB) are valid and supported
- There are no compliance red flags that would preclude award
Inaccuracies in Reps & Certs can result in delayed offers, rejections, or even legal consequences under the False Claims Act. For this reason, contractors are strongly encouraged to review their certifications prior to submitting any offer — and regularly thereafter.
Legal and Compliance Considerations
Because the certifications submitted through ORCA (and now SAM) are made under penalty of law, the legal implications of false statements are serious. Violations can trigger:
- Civil or criminal penalties
- Contract termination for cause
- Suspension or debarment from future contracting
- Reputational damage across government and industry
Contractors should ensure that only authorized personnel with accurate knowledge of the business complete and certify this section. It is also best practice to keep internal records and documentation to support the accuracy of all certifications made through SAM.
Legacy References to ORCA
Although ORCA has been retired for over a decade, the term still appears in:
- Older procurement documents and templates
- Training materials and legacy systems
- Vendor support conversations and informal references
Contractors encountering the term ORCA today should understand that it refers to what is now the Representations and Certifications section of SAM.gov. All functions formerly performed in ORCA have been migrated to SAM, and there is no need to access a separate system.
Conclusion
The Online Representations and Certifications Application (ORCA) played a pivotal role in modernizing how vendors submitted key compliance information to the federal government. Though it has been formally decommissioned and integrated into SAM.gov, the principles of centralized, transparent, and standardized certifications remain central to federal procurement today.
For contractors, maintaining accurate, current certifications within SAM is not just a procedural requirement — it is a legal obligation and a critical part of doing business with the U.S. government. Whether you’re pursuing a GSA Schedule, a competitive federal RFP, or a small business set-aside opportunity, your Reps & Certs — once filed in ORCA — are the first step toward eligibility and trust in the federal acquisition system.
