Does a joint venture need its own LLC and SAM registration, or can it just be an agreement between two firms?

A joint venture (JV) needs its own legal entity, such as an LLC, and its own SAM.gov registration, including a Unique Entity ID (UEI) and CAGE code, if it is to be the direct contractor to the federal government. For federal contracts, an unincorporated joint venture under a written agreement is generally not sufficient for direct contracting. The SBA rules for JVs, especially those formed for set-aside contracts, require the JV to be legally formed and registered. This new legal entity would then register in SAM.gov, obtaining its own UEI and CAGE code. This allows the government to track the JV as a distinct entity for contracting purposes, including assessing its size against the relevant NAICS code and tracking its past performance. While the JV's past performance will initially be derived from its members, the JV itself will accumulate its own record over time. State and local government procurements will have their own rules, which can vary widely, and often depend on the specific state procurement code or the portal's vendor guide. Always check those local requirements.