GSA Proposes Major New Certifications for Federal Grant Recipients: What You Need to Know

Hook

The General Services Administration (GSA) has announced a sweeping proposal that will reshape how every university, nonprofit, research lab, and hybrid contractor interacts with the federal grants ecosystem. Starting as early as March 2026, all entities seeking federal financial assistance through SAM.gov will need to certify that their Diversity, Equity, and Inclusion (DEI) programs do not violate federal anti-discrimination laws, that they comply with immigration statutes, and that they do not, directly or indirectly, support terrorism or public safety threats. Failure to comply—or false certification—could mean loss of funding and even criminal penalties under the False Claims Act (source).

Context

This proposed overhaul comes on the heels of Executive Order 14173, part of an ongoing shift under the Trump Administration that aims to eliminate what federal guidance refers to as "woke" or affirmative action-related mandates in contracting and financial assistance (source). The policies specifically target DEI initiatives perceived as exceeding federal law—such as mandatory diversity statements, policies setting race-based criteria for hiring or training, and requirements based on "lived experience" or "cultural competence."

The proposal joins a broader movement to tighten up compliance requirements for organizations receiving federal funds, potentially affecting more than 222,000 entities currently registered in SAM.gov. Alongside these DEI restrictions, the new rules would require organizations to affirm they do not knowingly employ or aid unauthorized immigrants, and that they do not support activities tied to terrorism or public violence.

The rulemaking is open for public comment until March 30 or 31, 2026, after which the changes are expected to go into effect for both new and renewing SAM.gov registrants (source). The GSA anticipates a major update to the representations and certifications system (FAR Reps & Certs) by March 24, 2026.

Impact

For Researchers and Universities

If your institution relies on federal research grants—even if you’re a public university or a major research hospital—these new certifications will be required to keep your SAM.gov profile up-to-date and maintain federal funding eligibility. Programs or hiring practices that leverage race-conscious criteria, require DEI statements, or use "diverse-slate" policies will come under scrutiny. Internal audits and policy revisions may be needed to meet these requirements (UNC coverage).

For Nonprofits and Museums

Organizations such as museums, arts nonprofits, or advocacy groups may need to reassess training, intern recruitment, and staff advancement pipelines. The Mid-Atlantic Association of Museums has called the changes "drastic," warning that they threaten current eligibility to receive grants if longstanding DEI initiatives run afoul of what the federal government deems lawful discrimination practices (MAAM statement).

For Hybrid Contractors and Grant Recipients

Entities that both contract with the government and receive grants will be doubly affected. Law firms advise that they begin reviewing internal DEI/HR policies, document processes, and prepare for enhanced compliance checks, as the new rules could later be mirrored in future contracting certifications. Failure to comply—or inaccurate self-certifications—exposes organizations to False Claims Act penalties.

Action

Immediate Steps for Grant Seekers

1. Audit Your Current Policies: Review all DEI, hiring, and training programs for potential conflicts with federal anti-discrimination law.
2. Consult Legal Counsel: Engage legal or compliance experts to interpret these changes for your specific situation, particularly if your programs involve race- or identity-based criteria.
3. Update Internal Controls: Tighten documentation, employee certifications, and HR data systems to handle compliance and evidence for audits.
4. Submit Feedback: Participate in the public comment period before March 30/31, 2026 to voice professional or institutional concerns (see GSA docket).

Preparing for Change

Entities renewing or registering for SAM.gov financial assistance after March 2026 must be ready to certify compliance with these new requirements, or risk delays—or denial—of future funding. Begin the review process early so policy changes can be implemented, debated, and ratified ahead of deadlines.

Outlook

While these changes are not yet final, grant seekers should prepare for a future where scrutiny of DEI programs and hiring policies is much stricter—and potentially subject to legal action. Watch for updates after the public comment period and further guidance from the GSA on how certification will be policed. With federal policy shifts in flux, organizations must keep compliance at the top of their funding strategies.

Granted AI helps organizations stay alert to policy shifts, compliance requirements, and new grant opportunities—so you stay ahead of the curve.