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ARTICLE · 24 SEPTEMBER 2026

What This Means In Practice: A Compliance Checklist

HR Unlimited
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Federal contractors face new certification requirements under Executive Orders 14173 and 14398, creating three layers of nondiscrimination attestation through SAM.gov, contract clauses, and FAR 52.222-90. Understanding what remains in force and implementing practical compliance steps before signing certifications can help contractors avoid costly violations and ensure their programs align with current federal anti-discrimination law.

United StatesEmployment and HR
Ahmed Younies
Ahmed Younies
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“VERIFY BEFORE YOU CERTIFY” — 3-MINUTE BRIEF, PART 3 OF 4

Parts 1–2 covered the rules and the three certification layers. This brief: what to actually do about it.

Recap: Contractors now certify nondiscrimination through SAM.gov representations, the EO 14173 certification embedded in each contract, and FAR 52.222-90. Here’s what stays in force separately, and the practical steps that follow.

Still Standing: Section 503 and VEVRAA

Not every affirmative-action-style obligation was affected by EO 14173 or EO 14398. Certification requirements tied to disability and veteran status come from separate statutes, Section 503 of the Rehabilitation Act and VEVRAA, and remain in force. Covered contractors must still maintain written AAPs for these two categories.

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