As we reported on January 22, January 29, and March 21, 2025, the Trump Administration’s Executive Orders aimed at diversity, equity, and inclusion (“DEI”) initiatives in both the federal government and the private sector are quickly impacting federal contracting.

Following the issuance of Executive Order 14173 and Executive Order 14151, the General Services Administration (GSA) has begun to withdraw DEI requirements for federal contracts. On February 15, 2025, the GSA announced two new class deviations making a number of changes to the procurement rules to implement the recently issued Executive Orders addressing DEI and climate change requirements. The GSA now requires that all federal contracts adhere immediately to the Trump Administration’s Executive Orders. Any contracts with fewer than six months remaining and no renewal options are currently exempt from mandatory compliance.

Following the issuance of the class deviations, the GSA in recent weeks has begun providing notices of immediate suspension to federal contractors and GSA Schedule holders if any DEI-related terms or language are included in:

• Marketing materials
• Labor category descriptions
• Job descriptions
• Recruitment postings
• Contractual terms or documentation

To prevent GSA schedule suspensions, federal contractors and clients should immediately take the following actions:

1. Review all contracts, labor descriptions, marketing materials, and websites for any DEI-related language or terms.
2. Remove or adjust all DEI-related language to prevent potential suspensions and disruptions to GSA schedules.
3. Monitor communications from the GSA and contracting officers closely to ensure timely responses to any compliance notices.

We strongly advise that you immediately review and adjust any of the materials mentioned above to prevent any contractual issues. Our team is here to help with any questions or guidance you may need concerning compliance actions.