SAM.gov in 2026: FAR Overhaul, New DEI + Immigration Certifications, and What Every Grantee Needs to Know

SAM.gov is undergoing its largest overhaul in years. The Revolutionary FAR Overhaul (RFO) is scheduled to reach SAM.gov's representations and certifications as early as Q1 2026, triggering system changes and updated attestations. Separately, the General Services Administration published a proposed rule on January 28, 2026 that would add new certification language addressing DEI, immigration status, and national security eligibility for recipients of federal financial assistance — with the public comment period closing March 31, 2026, per Feldesman analysis. For every small business, nonprofit, or research institution that touches federal money, 2026 is a year of significant SAM.gov compliance work.

Here's the short version: your registration itself doesn't need to be re-done, but the attestations you make during renewal will be different by year-end, and some registrants will need to update ownership and personnel disclosures more frequently than before.

What is the Revolutionary FAR Overhaul?

The Revolutionary FAR Overhaul is the largest rewrite of the Federal Acquisition Regulation in decades. It's a multi-agency effort to consolidate, simplify, and modernize the rules governing how the federal government buys goods and services and issues grants. The RFO began publishing sector-specific updates in mid-2025 and continues through 2026 and 2027.

For SAM.gov, the RFO means:

• Rewritten representations and certifications — the checkboxes and text attestations you sign during entity registration will be updated to reflect the new FAR language. Substance changes in several places, not just wording.
• Simplified small business self-certification — the small business definition itself is under active revision (the Trump administration has proposed allowing larger businesses to qualify), and the SAM.gov self-certification will follow whatever rule finalizes.
• New system flows for representations that were previously scattered across multiple screens.

The government committed to publishing "a full list of RFO-related changes to the SAM representations and certifications, as well as plans for system changes and implementation timelines, by the end of 2025." That list is now being rolled out in phases during 2026 (Crowell client alert).

What DEI, immigration, and national security certifications is GSA proposing?

The GSA proposed rule from January 28, 2026 would add new certification language for recipients of federal financial assistance — meaning grantees, not just contractors. The proposal:

• DEI certification — attestation that the organization does not operate programs described in the administration's definition of "unlawful DEI."
• Immigration certification — attestation regarding immigration status of covered employees and compliance with federal immigration law.
• National security eligibility — attestations covering foreign influence, adversary-nation ties, and export control compliance.

The public comment period closed March 31, 2026. GSA is now processing comments; expect the final rule sometime in Q3–Q4 2026, with implementation in SAM.gov following within 60-90 days of the final rule.

Legal challenges are likely. The DEI certification in particular is being watched by several civil rights organizations that have indicated they may challenge it as overbroad. If a court enjoins portions of the final rule, expect delays in implementation.

Does this affect current SAM.gov registrations?

Your current registration is not invalidated. But when you renew (registrations expire annually), you will attest to the updated language.

Practically:

• If your renewal is scheduled for the second half of 2026, plan to review the new certifications carefully before signing. Some organizations may need internal counsel to review the DEI and immigration attestations.
• If your renewal is scheduled for Q1 2026, you're renewing under the older representations. Your next renewal (Q1 2027) will hit the new versions.
• Grants.gov applications may require updated certifications even if your SAM.gov registration hasn't hit renewal yet. Read each NOFO's certifications section carefully — federal agencies have flexibility to require specific certifications at the application level.

What is the timeline for these changes?

| Milestone | Date | |---|---| | GSA proposed rule published | January 28, 2026 | | Public comment period closed | March 31, 2026 | | RFO changes begin rolling into SAM.gov | Q1 2026 (in progress) | | GSA final rule expected | Q3–Q4 2026 | | New certifications live in SAM.gov | Q4 2026 – Q1 2027 | | Full RFO integration complete | 2027 |

Dates can shift. Monitor SAM.gov announcements and the Federal Register for confirmed rulemaking dates.

What should grantees do now vs later?

Now (September 2026):

• Confirm your SAM.gov registration is not expired. If it expires in the next 60 days, start renewal now.
• Review the January 28 proposed rule so you know what certifications are coming. Even though the comment period closed, understanding the language now helps internal alignment when you're asked to attest.
• Verify beneficial ownership disclosures are current. SAM.gov ownership rules were tightened in early 2026 per Goodwin Law summary.
• Update your NAP (Name/Address/Phone) records so what SAM.gov shows matches your IRS, state Secretary of State, and D&B records — mismatches are the #1 silent reason federal grant applications get rejected. Free tools like Bitácora Corporativa exist for this exact tracking.

Later (Q4 2026 / early 2027):

• Review the finalized GSA rule as soon as it publishes.
• Confirm your organization can honestly sign each new certification. If the DEI certification poses a compliance question, consult counsel before signing.
• Update internal policies as needed to align with the certifications you're making.

How is SAM.gov different in 2026 vs 2025?

Beyond the coming rule changes, the entity registration process itself has been improved. SAM.gov rolled out registration refreshes on June 20, July 18, August 15, and September 12, 2025, per official announcements. Layouts are cleaner, help content is expanded, and parts of the registration flow have been reorganized — though the underlying data collected is unchanged.

Practical impact for a first-time registrant: registration is somewhat easier to navigate in 2026 than in 2024. Practical impact for existing registrants: your renewal experience will look and feel different, but the data you provide is the same.

Sources

• SAM.gov Announcements — Entity Registration Improvements
• Crowell: Not Just the FAR, SAM.gov Gets Overhauled Too
• BDO: Informing Federal Funding Recipients About GSA's Proposed SAM.gov Certification Updates
• Feldesman: New Proposed SAM.gov Registration Certifications for Grantees
• Goodwin Law: SAM.gov Ownership Disclosures

FAQ

Does the DEI certification affect me if I don't run DEI programs? You still have to sign the certification during registration renewal or grant application. If your organization doesn't operate programs covered by the certification, you sign honestly. Consult counsel if uncertain about what falls under the definition.

What happens if my SAM.gov registration expires while an application is pending? Federal agencies typically pause the application and give the applicant 60-90 days to renew. Some agencies (particularly NIH) treat an expired registration as automatic disqualification. Renew before the expiration.

Can I still apply for federal grants without SAM.gov registration? No. SAM.gov entity registration is required for every federal grant application. There are no exceptions for small businesses or first-time applicants.

How long does SAM.gov registration take for a new entity? 7–10 business days if everything goes smoothly (all documentation submitted correctly on first try). 3–4 weeks if validation queries come back — start early.

Does Windfall track SAM.gov changes? Yes — Windfall's daily sync of Grants.gov + SAM.gov Assistance Listings surfaces which grant programs have updated certification requirements. When you find a matching grant, Windfall flags the SAM.gov requirements in the match card so you know what to check. See your matches free.