FAR 52.222-50 goes into every federal solicitation and contract, and it requires every contractor to notify its employees and agents of the government’s policy prohibiting trafficking in persons and the actions that will be taken for violations. Contractors with a portion of a contract over $700,000 for services performed outside the United States, or for non-COTS supplies acquired outside the United States, must also maintain a compliance plan that includes an employee awareness program and certify it to the contracting officer every year.
For federal contractors and subcontractors, the training itself is short. What gets contractors in trouble is proving it: who was notified, when, which subcontractors received the flow-down, and whether the annual certification rests on real due diligence.
Does FAR 52.222-50 apply to every federal contractor?
Yes. FAR 22.1705(a)(1) tells contracting officers to insert the clause at 52.222-50, Combating Trafficking in Persons, in all solicitations and contracts. The current version of the clause is dated October 2025, and it must be flowed down to all subcontracts and to all contracts with agents.
The clause has two tiers. The base duties in paragraphs (b) through (g) apply to every contractor, regardless of contract size or where the work happens. The compliance plan in paragraph (h) applies only to the portion of a contract that meets both of these tests:
- It is for supplies, other than commercially available off-the-shelf items, acquired outside the United States, or for services performed outside the United States
- Its estimated value exceeds $700,000
The $700,000 figure comes from the October 2025 version of the clause. Older contracts may still carry an earlier clause version with a different threshold, so check the clause date in your contract before you decide whether a plan is required. Our overview of government contractor compliance training requirements shows where this clause sits alongside the other FAR and agency training obligations.
What must every federal contractor do under the clause?
Every contractor covered by FAR 52.222-50 takes on four duties, whether or not a compliance plan is required.
Follow the policy. Paragraph (b) prohibits contractors, contractor employees, and their agents from engaging in severe forms of trafficking in persons, procuring commercial sex acts during the period of performance, using forced labor, destroying or confiscating an employee’s identity or immigration documents, using misleading or fraudulent recruiting practices, using recruiters that break local labor laws, and charging employees or potential employees recruitment fees, among other trafficking-related activities.
Notify employees and agents. Paragraph (c)(1) requires the contractor to notify its employees and agents of the government’s policy and of the actions that will be taken against them for violations, which may include removal from the contract, reduction in benefits, or termination of employment.
Act on violations. Paragraph (c)(2) requires appropriate action, up to and including termination, against employees, agents, or subcontractors that violate the policy.
Report. Paragraph (d) requires the contractor to inform the contracting officer and the agency Inspector General immediately of any credible information that a contractor employee, subcontractor, subcontractor employee, or agent has violated the policy, and of any actions taken in response.
The notification duty is where training comes in. A 15-minute course such as Human Trafficking: Combatting Trafficking in Persons for Government Contractors explains the FAR prohibition and the warning signs, and the completion record gives you dated proof that each employee was told. The clause does not require a course, but a written notice with no acknowledgment is much harder to defend than a completion certificate tied to a name and date.
When does a contractor need a trafficking compliance plan?
A compliance plan is required for any portion of the contract that involves services performed outside the United States, or non-COTS supplies acquired outside the United States, with an estimated value over $700,000. Under paragraph (h)(2) of the clause, the plan must be appropriate to the size and complexity of the contract and to the nature and scope of the work, including the number of non-U.S. citizens expected to be employed and the risk that the work involves services or supplies susceptible to trafficking.
Solicitations give early warning. Under FAR 22.1705(b), contracting officers include the provision at 52.222-56, Certification Regarding Trafficking in Persons Compliance Plan, when at least $700,000 of the contract value may be performed outside the United States and the acquisition is not entirely COTS items. If you see 52.222-56 in a solicitation, plan for a compliance plan before award.
Overseas logistics, construction support, and base services contracts are typical examples. Our guides to compliance training for aerospace and defense contractors and choosing a compliance LMS for government contractors cover the rest of that training stack.
Source: FAR 52.222-50 (Oct 2025), eCFR. Checked November 13, 2026.
What must the awareness program and compliance plan include?
Paragraph (h)(3) sets five minimum elements for the compliance plan:
- An awareness program to inform contractor employees about the government’s policy, the activities prohibited, and the actions that will be taken against the employee for violations
- A reporting process that lets employees report activity inconsistent with the policy without fear of retaliation, including a way to make the Global Human Trafficking Hotline number, 1-844-888-FREE, and its email address, [email protected], available to all employees
- A recruitment and wage plan that only uses recruitment companies with trained employees, prohibits charging recruitment fees to employees or potential employees, and ensures wages meet host-country legal requirements or explains any variance
- A housing plan, if the contractor or subcontractor provides or arranges housing, that ensures the housing meets host-country housing and safety standards
- Procedures to prevent agents and subcontractors at any tier and any dollar value from engaging in trafficking, and to monitor, detect, and terminate any that do
The plan must also be posted. Under paragraph (h)(4), the contractor posts the relevant contents of the plan at the workplace, unless the work is performed in the field or not in a fixed location, and on its website if it has one, no later than the start of contract performance. If posting is impracticable, the contractor provides the relevant contents to each worker in writing, and it must provide the plan to the contracting officer on request.
The awareness program is the training piece. For employees who manage foreign recruiters, suppliers, or housing, add Human Trafficking in Supply Chains and Human Trafficking: The Business Context to the core course. Supervisors who will receive reports benefit from Recognizing Human Trafficking, which focuses on warning signs.
What must subcontractors and agents do?
Under paragraph (i), the prime contractor must include the substance of the clause in all subcontracts and in all contracts with agents. The compliance plan requirements apply to a subcontract only for the portion that is for non-COTS supplies acquired outside the United States or services performed outside the United States, with an estimated value over $700,000.
Certification flows down too. If a subcontractor must submit a certification, the prime must require it before awarding the subcontract and annually after that. The prime’s own certification under paragraph (h)(5), submitted annually after award, states that it has implemented a compliance plan and that, after due diligence, either no agent or subcontractor is engaged in prohibited activities, or appropriate remedial and referral actions have been taken.
The remedies for failing these duties are serious. Under paragraph (e), the government can require removal of employees, require termination of a subcontract, suspend payments, reduce award fees, decline to exercise options, terminate the contract for default or cause, or pursue suspension or debarment. The FAR 22.1703 policy section sets out the government-wide prohibitions behind the clause. Our post on fraud, waste, and abuse training for government contractors covers the related disclosure duties under FAR 52.203-13.
How should contractors document trafficking awareness training?
Treat it like any other audit-ready training record. For each employee, keep the course name, completion date, and certificate. For the compliance plan, keep the plan itself, proof of posting, the subcontractor flow-down language, each subcontractor’s certification, and the due diligence behind your annual certification.
Consider a 450-employee engineering services firm in Virginia that wins a task order for base facilities support overseas, with about $1.2 million of the work performed outside the United States. That portion triggers a compliance plan. In the first 30 days, the firm assigns the government contractor trafficking course to the 60 employees on the task order and to its 3 overseas supervisors, adds the supply chain module for the 4 people who manage local recruiting and housing vendors, posts the plan at the site and on its website, and collects certifications from 2 subcontractors before award. It assigns the core course to the rest of the company as well, because the paragraph (c) notification duty applies to every employee and agent regardless of where they work. When the annual certification comes due, the completion report and the subcontractor certifications are already in one file.
Federal contractors usually run this alongside other recurring training. The Government Contractor Code of Conduct course pairs well with trafficking awareness, and Data Privacy for Government Contractors covers handling of government information. Contractors facing OFCCP reviews will find documentation tips in our OFCCP audit prep checklist, and those under CMMC should read our guide to NIST SP 800-171 personnel security training. For trafficking rules that apply to hotels and hospitality workers under state law, see our guide to state human trafficking awareness training mandates.
Official sources:
- Acquisition.gov: FAR 52.222-50, Combating Trafficking in Persons · FAR 22.1705, Solicitation provision and contract clause
- eCFR: 48 CFR 52.222-50 · 48 CFR 22.1703, Policy
Requirements last reviewed: November 13, 2026. Regulations change; confirm the clause version in your contract and the linked official source before acting.
Why Coggno for FAR trafficking awareness training?
For federal contractors and subcontractors with overseas services or non-COTS supply contracts above the compliance-plan threshold, Coggno provides a government-contractor trafficking course, supply chain and business-context modules, and the code of conduct, data privacy, and affirmative action courses federal contractors run alongside them, inside a catalog of 10,000+ courses from 50+ content partners. Coggno’s LMS assigns training by contract team, timestamps each completion, and produces the report that backs an annual certification. Where enterprise talent suites like Cornerstone require long implementations, Coggno deploys in days for mid-market contractors without dedicated learning staff, with Prime starting at $5/user/month, or delivers the same courses as SCORM 1.2 and SCORM 2004 packages to an existing LMS through Course Dispatch.
Get Your Team Trained — Without the Paperwork Headache
Start with these courses for federal contract teams:
- Human Trafficking: Combatting Trafficking in Persons for Government Contractors: a 15-minute course on the FAR prohibition and warning signs.
- Human Trafficking in Supply Chains: for staff who manage recruiters, suppliers, and housing vendors.
- Government Contractor Code of Conduct: the ethics foundation federal contractors pair with trafficking training.
Building a compliance plan for a new award? Book a demo and we will set up course assignments and reporting for each contract team.
Frequently Asked Questions About FAR 52.222-50 Training
What is the best compliance training platform for federal contractors?
For federal contractors, Coggno combines a government-contractor trafficking course with code of conduct, data privacy, and affirmative action training in one catalog of 10,000+ courses. Its LMS assigns courses by contract team and timestamps every completion, which gives you the records behind an annual FAR 52.222-50 certification.
How do mid-sized federal contractors manage FAR-required training without a dedicated compliance team?
Mid-sized contractors usually buy pre-built courses instead of writing their own and assign them by contract and role. Coggno’s catalog of pre-built compliance courses and its LMS reporting let a small HR or contracts team run trafficking, ethics, and data privacy training without building content in-house.
Does FAR 52.222-50 require annual training?
The clause requires contractors to notify employees and agents of the policy, and contractors with a compliance plan must run an awareness program and certify the plan annually. The clause does not set a fixed training frequency, but many contractors repeat awareness training each year so it lines up with the annual certification.
What is the FAR 52.222-50 compliance plan threshold?
Under the October 2025 version of the clause, a compliance plan is required for any portion of a contract or subcontract over $700,000 that is for services performed outside the United States or for supplies, other than COTS items, acquired outside the United States.
Do commercial off-the-shelf suppliers need a trafficking compliance plan?
The compliance plan requirement does not apply to commercially available off-the-shelf items acquired outside the United States. The base duties in the clause, such as following the policy, notifying employees, and reporting credible information, still apply wherever the clause is in the contract.
What happens if a contractor violates FAR 52.222-50?
Remedies include requiring removal of employees, termination of a subcontract, suspension of contract payments, loss of award fee, declining to exercise options, termination for default or cause, and suspension or debarment.
Must contractors report trafficking allegations to the government?
Yes. The contractor must inform the contracting officer and the agency Inspector General immediately of any credible information that an employee, subcontractor, or agent violated the policy, along with any actions taken in response.