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

Hook

On January 28, 2026, the General Services Administration (GSA) published a proposed rule that could fundamentally change the compliance calculus for anyone seeking federal grants, cooperative agreements, or loans. The proposed revised certifications—required for every registration and renewal in SAM.gov—are poised to affect every recipient of federal financial assistance. Under the new regime, all grantees must attest to fresh, government-specified provisions related to antidiscrimination (especially around DEI), immigration, and terrorism—all under penalty of False Claims Act exposure and funding revocation.

With public comments due by March 30, 2026, this is more than regulatory housekeeping: it's a high-stakes, government-wide reset. Every research lab, nonprofit, higher education institution, and small business vying for federal support must be ready—or risk their eligibility.

Context

Traditionally, the compliance environment for federal funding recipients has been fragmented. Various agencies tacked on their own certifications, resulting in a confusing patchwork with uneven enforcement. But the new GSA proposal aims for a uniform government-wide standard, updating the basic requirements embedded in SAM.gov—the single portal all recipients use for registration and award management.

This action is rooted in two pivotal policies:

• Executive Order 14173 (January 31, 2025) on "Ending Illegal Discrimination and Restoring Merit-Based Opportunity."
• DOJ Memorandum (July 29, 2025): Guidance for Recipients of Federal Funding Regarding Unlawful Discrimination.

These orders reinterpret DEI programs through the lens of antidiscrimination law, requiring explicit certification that any federally funded activity—including those labeled as DEI—does not unlawfully discriminate based on race or color. The GSA's proposal also introduces, for the first time, new attestations by recipients that they will not fund terrorism or facilitate illegal immigration.

Impact

For Grantseekers and Recipients

If finalized, these changes will apply to all entities registering or renewing in SAM.gov, starting as soon as the rule takes effect (no firm date yet). This includes:

• Nonprofits and Charities
• Research Institutions and Universities
• Small Businesses seeking SBIR/STTR awards
• State and Tribal Governments receiving federal grants

Key impacts:

• Standardized Compliance: The once-fragmented field of certifications becomes unified—everyone answers to the same three core attestations.
• Policy Review Required: DEI initiatives, employment policies, and grant-funded activities must be reviewed to ensure no conflict with new legal interpretations. Misstatements—even unintentional—could spur severe penalties under the False Claims Act (31 U.S.C. § 3729) or criminal statutes.
• Programmatic Uncertainty: Nonprofits and advocacy groups warn these requirements could undermine missions focused on equity, potentially chilling effective DEI efforts and threatening existing funding.
• Increased Scrutiny: Federal agencies are signaled to more closely scrutinize representations in funding applications and ongoing compliance.

For Small Businesses and Contractors

At present, these certifications only affect financial assistance programs (grants, cooperative agreements, etc.), not FAR-based federal procurement contracts. However, a parallel rule for contractors is already under review at the Office of Management and Budget, suggesting broader changes may be imminent.

Action

With the comment period open until March 30, 2026, all present and prospective recipients should:

1. Review Your Policies Immediately: Scrutinize hiring, DEI/equity, ethics, and grant-funded program language for compliance with the proposed certifications' wording and intent.
2. Engage Staff and Legal Advisors: Leadership, compliance, HR, and program managers need to understand the stakes and coordinate an audit of risk areas.
3. Prepare Public Comments: If your organization sees risk, ambiguity, or burdensome impacts, submit comments via regulations.gov by the March 30 deadline. Advocacy, trade, and professional organizations can help amplify collective concerns.
4. Monitor Further Developments: Continue to track updates from GSA, federal agencies, and umbrella groups—especially as OMB's contractor certification rule nears finalization.

Outlook

This is the opening move in what will likely be an evolving federal compliance environment shaped by current executive priorities. Watch for the publication of final rules (timing TBD), potential legal challenges, and further agency-specific implementation guidance. The landscape for eligibility—and what must be certified to receive federal funds—will not be static.

Granted AI continuously monitors regulatory shifts like this and can help your team audit internal language, map risks, and draft compliance policies to keep your awards safe and eligible.