The scope of affected contracts—and the precise mechanics of compliance auditing—remain partially unclear as agencies begin implementation this week. The FAR amendments are due by May 25, and agency compliance reports by July 24. A legal challenge has already been filed, though its current status is undetermined.
Contractors should treat this as urgent. The compliance window is immediate, and the enforcement mechanisms are severe. Any federal contractor should audit current hiring, promotion, and resource allocation practices now, document compliance efforts, and prepare certification statements. Subcontractors face the same obligations. The order is part of a broader anti-DEI campaign spanning at least ten White House actions since January 20, 2025, making this a sustained policy direction rather than an isolated directive.