GSA’s New DEI Restrictions, Cybersecurity Requirements: What Federal Contractors Need to Know | Insights
Publish Date: 2026-06-17 18:12:00
Source Domain: www.hklaw.com
The U.S. General Services Administration (GSA) in April 2026 released a revised version of its GSA Form 3517B (the General Clauses) applicable to GSA leases. Coming on the heels of earlier revisions in December 2025 and March 2026, the April 2026 revision introduces a new clause addressing diversity, equity and inclusion (DEI) discrimination and a major consolidation of cybersecurity provisions under a single regulatory framework.
Notably, this impacts more than just new federal leases. In accordance with Executive Order (EO) 14398 discussed below, lessors with existing leases have begun to receive Docusign requests for signatures on proposed lease amendments that incorporate the DEI discrimination provisions, often accompanied by daily reminders.
An analysis of these new compliance obligations, the associated enforcement risk and options for lessors follows.
New DEI Discrimination Requirements
The most notable addition to the General Clauses is Federal Acquisition Regulation (FAR) 52.222-90, Addressing DEI Discrimination by Federal Contractors. This provision was added pursuant to EO 14398, issued on March 26, 2026, and related agency guidance.
The clause contains six elements:
- No Racially Discriminatory DEI Activities. Contractors may not engage in any racially discriminatory DEI activities, which the EO defines as disparate treatment based on race or ethnicity in the recruitment, employment (e.g., hiring, promotions), contracting (e.g., vendor agreements), program participation, or allocation or deployment of an entity’s resources
- Access to Books and Records. The contractor must furnish all information and reports, including access to books, records and accounts, as required by the contracting agency for purposes of ascertaining compliance.
- Remedies for Noncompliance. In the event of noncompliance by the contractor or a subcontractor, the contract may be canceled, terminated or suspended in whole or in part, and the contractor may be…
