The U.S. General Services Administration (GSA), which administers the System for Award Management (SAM), has proposed revising the certification requirements for recipients of federal financial assistance. The change would align SAM certifications with updated executive branch guidance, including Executive Order 14173 (“Ending Illegal Discrimination and Restoring Merit-Based Opportunity”) and a July 2025 Department of Justice (DOJ) memorandum addressing unlawful discrimination.

Currently, entities certify general compliance with federal anti-discrimination laws when registering or renewing in SAM. The proposed amendment would add more specific certification language, potentially requiring recipients to affirm they are not engaged in practices identified as impermissible under the DOJ’s updated interpretation of federal law—even where courts have not definitively resolved those interpretations. Certifications would likely be deemed material to payment decisions.

Although aspects of the DEI Executive Order have been challenged in court, recent Supreme Court precedent has limited the scope of nationwide injunctions, allowing much of the policy implementation to proceed.

Public comments on the proposal are open through March 30, 2026.