GSA Proposes Sweeping SAM.gov Certification Changes Tied to Anti-DEI Executive Order: What Grant Seekers Need to Know
March 26, 2026 · 4 min read
Claire Cummings
Hook: SAM.gov Set for Overhaul as GSA Proposes Major Certification Revisions
On January 28, 2026, the General Services Administration (GSA) unveiled a pivotal set of proposed revisions to the Financial Assistance General Certifications and Representations within SAM.gov. This announcement, rooted in the requirements of Executive Order 14173 (signed on January 21, 2025) and recent Department of Justice (DOJ) anti-discrimination guidance, introduces broad new certification demands linked to diversity, equity, and inclusion (DEI), immigration, and anti-terrorism policies.
All organizations seeking federal grants—numbering over 220,000 registered SAM.gov entities—will soon need to comply with these revised rules, some as early as after the March 30, 2026, public comment deadline. The resulting eligibility and compliance changes are poised to ripple through the nonprofit, research, and business sectors.
Context: Why This SAM.gov Proposal Matters
Federal organizations, nonprofits, universities, and businesses are required to register in SAM.gov for any federal grant, cooperative agreement, or loan. Since 2020, the landscape of certifications has grown increasingly complex, especially with the Biden Administration’s 2021 executive actions and evolving legal challenges to DEI programs since the Supreme Court’s 2023 affirmative action decision (Students for Fair Admissions v. Harvard).
Now, with Executive Order 14173, the pendulum has swung toward restricting and auditing DEI practices in all federally funded organizations. GSA’s new proposal aims to align all federal assistance certifications with the most current anti-discrimination and anti-DEI mandates, as seen in DOJ guidance from July 29, 2025. The changes also reflect a significant increase in exposure for grant recipients—expanding false statement and False Claims Act liability.
These changes come amid a broad federal push to modernize acquisition and assistance regulations. For example, related updates to the Federal Acquisition Regulation's (FAR) Representations & Certifications were released March 24, 2026, further underscoring the pace and scope of these reforms. Organizations relying on continued federal support must treat the coming months as a crucial period of adjustment.
Impact: What This Means for Grant Seekers
1. Direct Impact on Eligibility and Funding:
Any organization applying for federal funds—grants, cooperative agreements, loans, insurance, or even direct appropriations—will be required to newly certify that their programs do not involve "illegal DEI" practices or otherwise run afoul of federal anti-discrimination laws. This requirement spells uncertainty for nonprofits, research institutions, and small businesses with existing DEI programming, even if those initiatives were compliant under previous federal guidance.
False attestations carry strong repercussions: applicants could face not only grant termination and exclusion from future funding, but also civil and criminal penalties under the False Claims Act. Essentially, the margin for misunderstanding or good-faith errors is shrinking.
2. Increased Compliance Burden:
Expanding certifications on immigration and anti-terrorism add yet another layer of compliance and documentation. Legal, consulting, and industry groups urge all organizations to audit DEI, hiring, and admissions policies—especially those previously designed to meet now-repealed executive orders or affirmative action rules. Internal training and compliance documentation will be more mission-critical than ever.
3. Uncertainty and Sector-Wide Concern:
Nonprofits and associations—including the Mid-Atlantic Association of Museums and the National Council of Nonprofits—have raised alarm regarding both liability risks and operational disruption. Many fear that expected vagueness in defining "illegal DEI" will not protect well-intentioned programs from investigation or litigation. Ongoing court cases and further regulatory clarifications will continue to affect how these rules are interpreted and enforced.
Action: Steps to Take Now
1. Review and Comment:
Every organization registered in SAM.gov, or those planning to apply for federal funding, should closely review the proposed GSA changes (Federal Register link). The public comment period is open until March 30, 2026. Submit concerns—especially regarding program impact, compliance confusion, or liability risks—either as an individual organization or through your national association (see National Council of Nonprofits Guide for sample comments).
2. Audit Internal Policies:
Conduct an immediate review of all DEI, immigration, and anti-terrorism related policies and training programs. Ensure your current practices align with all laws and newly cited executive orders. Document relevant compliance efforts and halt any programs whose legality is uncertain until further guidance is issued.
3. Coordinate Compliance:
As risk management becomes more complex, coordinate with legal, HR, compliance, and programmatic leadership to prepare for new certifications. Update internal processes so new and renewing applicants understand updated attestations and their legal liability.
Outlook: What to Watch Next
Once the March 30, 2026 comment deadline closes, GSA is expected to move quickly—potentially implementing these new SAM.gov certifications soon after, alongside the broader FAR modernization. Many sector groups have signaled possible legal challenges, particularly on the definition and enforcement of “illegal DEI” practices, meaning further guidance or judicial review is possible into late 2026 and beyond. Stay alert for updates from GSA, DOJ, and your primary funding agency.
As the grant landscape shifts, Granted AI helps organizations stay current on evolving compliance requirements and federal eligibility rules.
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