Compliance Stuff

On March 26, 2026, President Trump issued  Executive Order 14398, Addressing DEI Discrimination by Federal Contractors , which instructed  . Consistent with deadlines established by the executive order, the Federal Acquisition Regulatory Council (FAR Council)  issued a memorandum  dated April 17, 2026, providing guidance to agencies that issue contracts to support their implementation of EO 14398.  The memorandum informs agencies that they must use the new contract clause at FAR 52.222-90 as follows: Beginning April 24, 2026, the new clause must be inserted in new solicitations and resulting contracts that are valued over the micro-purchase threshold, including contracts for commercial products and services. The micro-purchase threshold is $15,000. Open solicitations are also to be amended to incorporate the new clause.  Contracting officers are further instructed to “make every effort to bilaterally modify existing contracts by July 24, 2026 .” If a contr...

On March 26, 2026, President Donald Trump signed an executive order (EO) titled “ Addressing DEI Discrimination by Federal Contractors ” that, for the first time, attaches direct contractual consequences to diversity, equity, and inclusion (DEI) practices in federal contracting. 00:00 10:59 Quick Hits On March 26, 2026, President Trump issued an executive order (EO) with broad applicability to federal contractors and subcontractors, but certain agreements would not likely be covered by the EO, including Other Transaction Agreements (OTAs), cooperative agreements, and grants. The EO defines “racially discriminatory DEI activities” as disparate treatment based on race or ethnicity across hiring , promotions, vendor agreements, training, and program participation—a notable departure from earlier EOs that used the phrase “unlawful DEI” without defining it. Enforcement authority appears to rest with individual contracting agencies, which may terminate or suspend contracts and initiate deba...

Federal procurement is in a period of significant change that will reshape both how agencies buy goods and services and how contractors manage compliance. 0:00 8:20 The Federal Acquisition Regulation (FAR) is moving away from highly prescriptive, checklist-driven rules toward a more principles-based framework that emphasizes judgment and discretion and necessitates well-developed internal controls. The FAR overhaul’s stated goal is to streamline acquisitions, reduce non-statutory burdens, and expand competition, especially for smaller vendors. For contractors, this shift places greater importance on disciplined risk management —and the most resilient approach is a proactive compliance framework that integrates procurement, employment, and operational practices to manage regulatory exposure holistically. Quick Hits The FAR overhaul is shifting f ederal procurement from prescriptive regulatory procedures to a principles-based framework that relies more heavily on contractor judgment an...