Compliance Stuff

The biggest danger may be misreading the order—and creating new exposure in the process. On March 26, 2026, President Trump issued an executive order (EO) titled “ Addressing DEI Discrimination by Federal Contractors .” Read at the headline level, the order can sound like another broad anti-diversity, equity, and inclusion (DEI) pronouncement. Read as a procurement directive, however, it is something more concrete and more consequential: a command to federal agencies to begin inserting a mandatory clause into covered contracts and contract-like instruments, including subcontracts and lower-tier subcontracts, within 30 days. That shift, from messaging to mechanics, is the real story. What and When The order defines “racially discriminatory DEI activities” as disparate treatment based on race or ethnicity in recruitment, employment, contracting, program participation, or the allocation or deployment of an entity’s resources. It separately defines “program participation” broadly to inc...

The Federal Acquisition Service (FAS) of the General Services Administration (GSA)  revealed on October 17, 2025 , that it will issue a Multiple Award Schedule (MAS) Solicitation 47QSMD20R0001 “refresh” sometime in November 2025 . While GSA allowed the contracting community 10 business days to submit comments—until October 31, 2025 —as MAS contract holders know, GSA issues refreshes from time to time so that changes are made uniformly in recognition of shifts in policy, regulations, or statutes. Administering MAS contracts in this way allows GSA to curate terms in a consistent manner for contractual vehicles at all stages of performance, as contractors perform orders at different times. Refresh #30 The incoming November changes, “Refresh #30,” promise to be significant because they will make several modifications to the overall MAS Solicitation. In GSA’s  Summary of Changes , Refresh #30 will update numerous clauses and provisions to align the MAS Solicitation with deviations...