Build America, Buy America · 2 CFR 184
Build America, Buy America · 2 CFR 184
Buy America proof keeps your HUD housing dollars flowing.
Buy America proof keeps your HUD housing dollars flowing.
Buy America proof keeps your HUD housing dollars flowing.
Buy America proof keeps your HUD housing dollars flowing.
BABA already applies to HUD-funded multifamily housing of five or more units, and every covered dollar demands American-made materials. Fall short on proof and you face funding clawbacks, rip-and-replace, debarment, and False Claims Act treble damages. Certivo gets you audit-ready in about a week.
$5,000/mo
$5,000/mo
Live in ~1 week
Live in ~1 week
Month-to-month, no obligation
Month-to-month, no obligation
⚠ In effect now
⚠ In effect now
⚠ In effect now
HUD's phased implementation is complete, so the Buy America Preference applies today.
HUD's phased implementation is complete, so the Buy America Preference applies today.
Applies to HUD-funded multifamily housing of 5+ units
Applies to HUD-funded multifamily housing of 5+ units
1 to 4 unit developments are treated as private and exempt
1 to 4 unit developments are treated as private and exempt
Project and product waivers are backlogged, often 6+ months
Project and product waivers are backlogged, often 6+ months
Requirement status
Requirement status
Requirement status
Active
Active
Active
Policy is in flux: a HUD RFI and pending legislation could change how BABA applies to housing. Current as of July 2026.
What BABA requires
Three material categories. Three domestic-content tests.
Since May 14, 2022, every infrastructure project using federal financial assistance has to meet all three. The requirement flows down to every subcontract, purchase order, and supplier tier.
Since May 14, 2022, every infrastructure project using federal financial assistance has to meet all three. The requirement flows down to every subcontract, purchase order, and supplier tier.
Since May 14, 2022, every infrastructure project using federal financial assistance has to meet all three. The requirement flows down to every subcontract, purchase order, and supplier tier.
100%
100%
100%
100%
Iron & steel
Iron & steel
Iron & steel
All manufacturing processes, from initial melting through the application of coatings, must occur in the United States.
All manufacturing processes, from initial melting through the application of coatings, must occur in the United States.
55%
55%
55%
55%
Manufactured products
Manufactured products
Manufactured products
Manufactured in the U.S. with at least 55% domestic component cost, plus U.S. final assembly. Thresholds are rising by program.
Manufactured in the U.S. with at least 55% domestic component cost, plus U.S. final assembly. Thresholds are rising by program.
100%
100%
100%
100%
Construction materials
Construction materials
Construction materials
All manufacturing processes for each material must take place in the United States.
All manufacturing processes for each material must take place in the United States.
If any portion of a project uses federal funds, BABA applies to the entire project. Federal money often flows through state agencies, so a project you think of as "state-funded" may still be covered.
If any portion of a project uses federal funds, BABA applies to the entire project. Federal money often flows through state agencies, so a project you think of as "state-funded" may still be covered.
If any portion of a project uses federal funds, BABA applies to the entire project. Federal money often flows through state agencies, so a project you think of as "state-funded" may still be covered.
The cost of getting it wrong
A certification you can't back up is the expensive kind.
On the jobsite
On the jobsite
Rip & replace
Rip & replace
Rip & replace
Rip & replace
Non-compliant work removed and reinstalled at your own cost.
Non-compliant work removed and reinstalled at your own cost.
On the award
On the award
Funding clawback
Funding clawback
Funding clawback
Funding clawback
Agencies can reclaim federal dollars already spent and delay the project.
Agencies can reclaim federal dollars already spent and delay the project.
On your future
On your future
Debarment
Debarment
Debarment
Debarment
Lose the contract and your eligibility to bid federal work.
Lose the contract and your eligibility to bid federal work.
On the paperwork
On the paperwork
Up to $28,619
Up to $28,619
Up to $28,619
Per false claim under the False Claims Act, on top of treble damages.
Per false claim under the False Claims Act, on top of treble damages.
The trap: the False Claims Act's standard includes "reckless disregard," so a careless certification can create liability even without intent. DOJ recovered a record $6.8B in FCA cases in FY2025, much of it from whistleblowers.
The trap: the False Claims Act's standard includes "reckless disregard," so a careless certification can create liability even without intent. DOJ recovered a record $6.8B in FCA cases in FY2025, much of it from whistleblowers.
The trap: the False Claims Act's standard includes "reckless disregard," so a careless certification can create liability even without intent. DOJ recovered a record $6.8B in FCA cases in FY2025, much of it from whistleblowers.
The offer
The Certivo BABA Starter Package for HUD Residential Projects
An AI-powered platform, backed by human compliance experts, that turns scattered supplier data into defensible, audit-ready Buy America proof across every supplier tier. No long onboarding cycle. No long-term contract.
An AI-powered platform, backed by human compliance experts, that turns scattered supplier data into defensible, audit-ready Buy America proof across every supplier tier. No long onboarding cycle. No long-term contract.
An AI-powered platform, backed by human compliance experts, that turns scattered supplier data into defensible, audit-ready Buy America proof across every supplier tier. No long onboarding cycle. No long-term contract.
An AI-powered platform, backed by human compliance experts, that turns scattered supplier data into defensible, audit-ready Buy America proof across every supplier tier. No long onboarding cycle. No long-term contract.
✓ Supplier certifications collected and tracked at every tier
✓ Component-level BOMs mapped to domestic-content thresholds
✓ Mill certs, invoices, and supplier letters in any format
✓ Audit-ready records you can produce on demand
✓ Flow-down obligations handled across subs and POs
✓ Waiver guidance when domestic sourcing isn't available
✓ Supplier certifications collected and tracked at every tier
✓ Component-level BOMs mapped to domestic-content thresholds
✓ Mill certs, invoices, and supplier letters in any format
✓ Audit-ready records you can produce on demand
✓ Flow-down obligations handled across subs and POs
✓ Waiver guidance when domestic sourcing isn't available
✓ Supplier certifications collected and tracked at every tier
✓ Component-level BOMs mapped to domestic-content thresholds
✓ Mill certs, invoices, and supplier letters in any format
✓ Audit-ready records you can produce on demand
✓ Flow-down obligations handled across subs and POs
✓ Waiver guidance when domestic sourcing isn't available
✓ Supplier certifications collected and tracked at every tier
✓ Component-level BOMs mapped to domestic-content thresholds
✓ Mill certs, invoices, and supplier letters in any format
✓ Audit-ready records you can produce on demand
✓ Flow-down obligations handled across subs and POs
✓ Waiver guidance when domestic sourcing isn't available
BABA Starter Package · HUD residential
BABA Starter Package · HUD residential
BABA Starter Package · HUD residential
$5,000/ month
$5,000/ month
$5,000/ month
✓ Up and running in as little as a week
✓ Up to 10 concurrent projects covered
✓ Month-to-month, cancel anytime
✓ No setup fees, no obligation
✓ Up and running in as little as a week
✓ Up to 10 concurrent projects covered
✓ Month-to-month, cancel anytime
✓ No setup fees, no obligation
✓ Up and running in as little as a week
✓ Up to 10 concurrent projects covered
✓ Month-to-month, cancel anytime
✓ No setup fees, no obligation
✓ Up and running in as little as a week
✓ Up to 10 concurrent projects covered
✓ Month-to-month, cancel anytime
✓ No setup fees, no obligation
Book a 15-min call
Book a 15-min call
Book a 15-min call
Book a 15-min call
A quick call is all it takes to see if it fits.
A quick call is all it takes to see if it fits.
A quick call is all it takes to see if it fits.
Why Certivo
Proof you can certify with confidence.
24/7 proactive monitoring
24/7 proactive monitoring
24/7 proactive monitoring
Agency rules, thresholds, and waivers shift constantly. The platform tracks the changes so your certifications stay current.
Agency rules, thresholds, and waivers shift constantly. The platform tracks the changes so your certifications stay current.
Agency rules, thresholds, and waivers shift constantly. The platform tracks the changes so your certifications stay current.
Human compliance experts
Human compliance experts
Human compliance experts
Real specialists help you interpret 2 CFR 184, handle edge cases, and prepare for federal audits.
Real specialists help you interpret 2 CFR 184, handle edge cases, and prepare for federal audits.
Real specialists help you interpret 2 CFR 184, handle edge cases, and prepare for federal audits.
Bring data in any format
Bring data in any format
Bring data in any format
Mill certs, supplier letters, BOMs, ERP exports, PDFs. Hand it over however it lives; we structure and map it.
Mill certs, supplier letters, BOMs, ERP exports, PDFs. Hand it over however it lives; we structure and map it.
Mill certs, supplier letters, BOMs, ERP exports, PDFs. Hand it over however it lives; we structure and map it.
No hallucinations
No hallucinations
No hallucinations
Deterministic AI produces consistent, traceable domestic-content determinations you can stand behind in an audit.
Deterministic AI produces consistent, traceable domestic-content determinations you can stand behind in an audit.
Deterministic AI produces consistent, traceable domestic-content determinations you can stand behind in an audit.
How it works
From first call to audit-ready in about a week.
15-minute intro call
15-minute intro call
We learn your projects, funding sources, and where your supply-chain data lives today.
We learn your projects, funding sources, and where your supply-chain data lives today.
We ingest and map
We ingest and map
Send supplier docs and BOMs in any format. We map every component to the right domestic-content rule.
Send supplier docs and BOMs in any format. We map every component to the right domestic-content rule.
You certify with proof
You certify with proof
Work from one platform with continuous monitoring, expert support, and audit-ready records on demand.
Work from one platform with continuous monitoring, expert support, and audit-ready records on demand.
One platform, every domestic-content regime
BABA is rarely the only rule on a project.
Federal domestic-preference laws overlap and use different tests. The same platform keeps them straight so you apply the right standard every time.
Federal domestic-preference laws overlap and use different tests. The same platform keeps them straight so you apply the right standard every time.
Federal domestic-preference laws overlap and use different tests. The same platform keeps them straight so you apply the right standard every time.
BABA · Federally funded infrastructure
BAA · Buy American Act, direct procurement
AIS · American Iron & Steel, EPA water
TAA · Trade Agreements Act
Berry Amendment · DoD textiles & tools
FTC "Made in USA" · Marketing claims
BABA · Federally funded infrastructure
BAA · Buy American Act, direct procurement
AIS · American Iron & Steel, EPA water
TAA · Trade Agreements Act
Berry Amendment · DoD textiles & tools
FTC "Made in USA" · Marketing claims
BABA · Federally funded infrastructure
BAA · Buy American Act, direct procurement
AIS · American Iron & Steel, EPA water
TAA · Trade Agreements Act
Berry Amendment · DoD textiles & tools
FTC "Made in USA" · Marketing claims
BABA · Federally funded infrastructure
BAA · Buy American Act, direct procurement
AIS · American Iron & Steel, EPA water
TAA · Trade Agreements Act
Berry Amendment · DoD textiles & tools
FTC "Made in USA" · Marketing claims
BABA · Federally funded infrastructure
BAA · Buy American Act, direct procurement
AIS · American Iron & Steel, EPA water
TAA · Trade Agreements Act
Berry Amendment · DoD textiles & tools
FTC "Made in USA" · Marketing claims
BABA · Federally funded infrastructure
BAA · Buy American Act, direct procurement
AIS · American Iron & Steel, EPA water
TAA · Trade Agreements Act
Berry Amendment · DoD textiles & tools
FTC "Made in USA" · Marketing claims
BABA · Federally funded infrastructure
BAA · Buy American Act, direct procurement
AIS · American Iron & Steel, EPA water
TAA · Trade Agreements Act
Berry Amendment · DoD textiles & tools
FTC "Made in USA" · Marketing claims
BABA · Federally funded infrastructure
BAA · Buy American Act, direct procurement
AIS · American Iron & Steel, EPA water
TAA · Trade Agreements Act
Berry Amendment · DoD textiles & tools
FTC "Made in USA" · Marketing claims
other domestic-preference rules
other domestic-preference rules
other domestic-preference rules
Frequently Asked Questions
Does BABA even apply to our project?
If any part of an infrastructure project uses federal financial assistance obligated after May 14, 2022, BABA applies to the whole project. That covers highways, water, transit, airports, broadband, energy, and public buildings. Federal money often flows through state agencies, so a project you consider "state-funded" may still be covered. A short call confirms your exposure.
Isn't a "Made in USA" label enough?
No. A marketing label is not a BABA certification. BABA has three separate domestic-content standards, and you need product- and project-specific certification letters backed by documentation. A generic "our products are American-made" statement will not hold up.
What about waivers?
Public-interest, non-availability, and unreasonable-cost waivers exist, but each requires a written request, a public comment period, and agency plus OMB review. They take weeks to months, so they are not a last-minute escape hatch. We help you see early whether one is worth pursuing.
What data do you need from us?
Whatever you already have: supplier certifications, bills of materials, mill certs, invoices, ERP exports. Hand it over in any format. The platform structures it and maps each component to the right domestic-content threshold.
How is this better than spreadsheets?
BABA now demands continuous verification and audit-ready records on demand across every supplier tier. Spreadsheets break under flow-down and constant rule changes; the platform keeps your proof current automatically and ready to produce.
Can we trust AI with False Claims Act exposure on the line?
The platform uses deterministic AI that produces consistent, traceable determinations, reviewed by human experts. That matters because the FCA's standard includes "reckless disregard," so a careless certification can create liability even without intent. Traceable proof is the point.
I'm not the right person for this.
No problem. Forward this to whoever owns procurement, project controls, or compliance. The 15-minute call works for anyone trying to understand exposure and options.
Does BABA even apply to our project?
If any part of an infrastructure project uses federal financial assistance obligated after May 14, 2022, BABA applies to the whole project. That covers highways, water, transit, airports, broadband, energy, and public buildings. Federal money often flows through state agencies, so a project you consider "state-funded" may still be covered. A short call confirms your exposure.
Isn't a "Made in USA" label enough?
No. A marketing label is not a BABA certification. BABA has three separate domestic-content standards, and you need product- and project-specific certification letters backed by documentation. A generic "our products are American-made" statement will not hold up.
What about waivers?
Public-interest, non-availability, and unreasonable-cost waivers exist, but each requires a written request, a public comment period, and agency plus OMB review. They take weeks to months, so they are not a last-minute escape hatch. We help you see early whether one is worth pursuing.
What data do you need from us?
Whatever you already have: supplier certifications, bills of materials, mill certs, invoices, ERP exports. Hand it over in any format. The platform structures it and maps each component to the right domestic-content threshold.
How is this better than spreadsheets?
BABA now demands continuous verification and audit-ready records on demand across every supplier tier. Spreadsheets break under flow-down and constant rule changes; the platform keeps your proof current automatically and ready to produce.
Can we trust AI with False Claims Act exposure on the line?
The platform uses deterministic AI that produces consistent, traceable determinations, reviewed by human experts. That matters because the FCA's standard includes "reckless disregard," so a careless certification can create liability even without intent. Traceable proof is the point.
I'm not the right person for this.
No problem. Forward this to whoever owns procurement, project controls, or compliance. The 15-minute call works for anyone trying to understand exposure and options.
Don't certify what you can't prove.
Don't certify what you can't prove.
Don't certify what you can't prove.
Don't certify what you can't prove.
See how fast Certivo can give your team audit-ready Buy America proof across the supply chain. No pressure, no commitment, just a clear picture of where you stand.
See how fast Certivo can give your team audit-ready Buy America proof across the supply chain. No pressure, no commitment, just a clear picture of where you stand.
See how fast Certivo can give your team audit-ready Buy America proof across the supply chain. No pressure, no commitment, just a clear picture of where you stand.
Book a 15-min call
Book a 15-min call
Book a 15-min call
$5,000/mo
$5,000/mo
month-to-month
month-to-month
live in about a week
live in about a week