Informing Federal Funding Recipients About GSA’s Proposed SAM.gov Certification Updates

A Quiet Administrative Proposal With Broad Practical Reach

A proposal published by the General Services Administration (GSA) on January 28, 2026 may have significant practical implications for organizations that rely on federal financial assistance. At issue is a proposed revision to the Financial Assistance General Certifications and Representations used in SAM.gov, the registration system that many organizations must use before they can receive federal grants, cooperative agreements, loans, insurance, direct appropriations, and other forms of federal financial assistance. Comments are due by March 30, 2026. 

On its face, the proposal is framed as a revision to an existing information collection under the Paperwork Reduction Act. But for recipients, the issue is more consequential than routine paperwork. SAM certifications are organizational attestations made by an authorized official. They sit close to the front end of the funding lifecycle and can influence eligibility, award processing, and later compliance review. That makes the proposal a governance and risk-management issue as much as an administrative one. 

GSA states that the proposed amendment would update the certification package to align with updated executive branch guidance, including the Department of Justice’s (DOJ’s) July 29, 2025 guidance for recipients of federal funding regarding unlawful discrimination and Executive Order (EO) 14173, Ending Illegal Discrimination and Restoring Merit-Based Opportunity. The notice says the proposed revisions would apply to entities receiving grants, cooperative agreements, and financial assistance such as loans, insurance, and direct appropriations. 

“SAM registration is not just a data-entry exercise. For many recipients, it is part of the federal compliance architecture.”

Why SAM.gov Matters

SAM.gov is the federal government’s central registration system for entities that seek to do business with, or receive certain forms of support from, the federal government. For financial assistance recipients, GSA’s notice explains that applicants and recipients generally must register in SAM and maintain an active registration with current information throughout the period they have an active federal award, or while an application or plan is under consideration, unless an exception applies. 

That requirement matters because SAM is not merely a database of entity information. It is also the platform through which organizations make certifications and representations that the federal government may rely on in connection with financial assistance. Those certifications can affect eligibility, help frame award conditions, and become relevant if questions arise later about whether a recipient accurately represented its compliance posture. 

GSA also notes that the collection supports prime awardee reporting obligations under the Federal Funding Accountability and Transparency Act. In practical terms, which reinforces the point that SAM is part of the federal award control environment, not just a registration form. 

What GSA Proposed To Change

The Federal Register notice says the proposal would revise the Financial Assistance General Certifications and Representations to align with updated executive branch guidance, specifically citing DOJ’s July 29, 2025 guidance and EO 14173. EO was signed on January 21, 2025 and published in the Federal Register on January 31, 2025. 

At a high level, public summaries of the proposal indicate that GSA would add three new certifications and revise at least one existing certification. The reported subject areas include unlawful discrimination in federally funded programs, including programs labeled as DEI or DEIA; certain immigration-related conduct; and funding or facilitation of violence, terrorism, or other illegal activities threatening public safety or national security. Public summaries also indicate that GSA would revise an existing certification related to freedom of speech and religious liberty. These descriptions come from public summaries of the proposed certification text rather than from the short Federal Register summary alone, so recipients should review the proposal text directly when developing internal positions or comment letters. 

The broader reason many recipients are paying attention is structural. This is not a proposed term for one agency or one program. It is a proposed revision to a SAM certification framework that can reach broadly across the federal financial assistance ecosystem. That means the practical implications could extend across multiple recipient types and sectors. 

“The significance here is not just what the proposal says, but where it sits in the funding process.”

Who Should Pay Attention

This proposal should be on the radar of any organization that depends on federal financial assistance and uses SAM as part of that process. GSA describes the collection as applying to prime financial assistance recipients, subject to certain exceptions, which includes:

• State and local governments. Includes agencies that receive direct federal support or administer pass-through federal programs. 
• School districts and charter networks. Educational entities that apply for or receive federal financial assistance and must maintain SAM registration. 
• Higher education institutions. Colleges and universities that rely on federal grants or other financial assistance should view this as a potentially important development in the pre-award and renewal process. 
• Head Start and early childhood providers. These entities often operate in a complex federal funding environment where centralized compliance and decentralized operations must work together. 
• Nonprofits and subrecipients. Nonprofits receiving direct federal awards or significant pass-through support may need to assess both SAM-facing responsibilities and downstream compliance expectations. 
• Pass-through entities. Although the SAM certification is made by the entity registering in the system, pass-through entities may still need to think about downstream communications, monitoring expectations, and subaward language if the final framework changes the practical compliance landscape. This last point is an operational inference rather than an express statement in the notice. 

Practical Implications For Recipients

1. Governance. In many organizations, SAM registration is handled by grants administration, procurement, finance, or sponsored programs teams. But where certifications become more substantive, the governance question becomes more important: who is the authorized official, what review happens before submission, and which departments are involved in validating what the organization is certifying? The proposal suggests that legal, compliance, human resources, procurement, program leadership, and grants management may all need a seat at the table. 
2. Policy Alignment. Because GSA says the revisions are intended to align with updated executive branch guidance, organizations may want to compare the proposal against existing policies, training materials, internal guidance, and issue-escalation channels. The purpose is not to overreact before final action is taken. The purpose is to understand whether the organization has a disciplined process for evaluating certification language before an authorized official clicks “submit.” 
3. Documentation. Certifications made on behalf of the organization are easier to support when the organization has clear delegated authority, policy documentation, training records, and internal review memoranda. That is especially true when multiple departments own pieces of the information relevant to a certification. This is also where burden becomes real: an update that appears simple at the portal level may require considerable internal coordination behind the scenes. GSA’s own notice invites comments on practical utility, burden, clarity, and ways to minimize burden, which makes documentation and workflow impacts fair game for commenters. 
4. Flow-down and communication. Prime recipients and pass-through entities may need to consider whether changes in SAM-facing certifications affect how they communicate expectations to subrecipients, contractors, and program partners. The Federal Register notice does not spell out a specific flow-down requirement in this context, so organizations should be careful not to overstate that point. Still, from a practical compliance standpoint, downstream communication is likely to be part of many organizations’ responses. 
5. Risk Management. The certification framework includes language that the authorized official may be subject to criminal prosecution under 18 U.S.C. § 1001 or civil liability under the False Claims Act for false, fictitious, or fraudulent information. That language does not mean every disagreement over compliance becomes a fraud case. It does mean recipients should approach the certifications as formal representations that merit careful internal review. 

“For many recipients, the operational question is simple: who inside the organization is comfortable standing behind the certification, and on what basis?”

What Recipients Can Do Now

Identify all forms of federal financial assistance the organization receives, including both direct and pass-through funding. That inventory helps leadership understand how broadly the issue may matter across the enterprise. 

Confirm who submits SAM registrations and certifications, who reviews them, and whether that workflow reflects the actual risk profile of the organization. In some cases, SAM processes may have evolved over time without a corresponding update to governance or delegated authority. 

Review the current compliance framework, including policies, training, reporting channels, and escalation processes. Organizations with decentralized operations may want to assess whether compliance information is adequately shared across functions before certifications are made. 

Coordinate across teams. Finance, grants management, legal, procurement, human resources, compliance, and program leadership may each hold relevant pieces of the picture. Proposals like this often expose process gaps that are less about substantive law and more about fragmented internal ownership. This is an operational inference, but it is a common one for government-wide certification changes. 

Finally, consider whether to submit a comment. The notice expressly invites comments on necessity, utility, burden, clarity, and ways to minimize burden. That gives organizations a straightforward path to provide practical, nonpartisan feedback grounded in implementation realities. 

What Boards, CFOs, and Compliance Leaders Should Ask Now

1. Who owns SAM registration and certification in our organization?
2. Who is the authorized official, and what internal review happens before certifications are submitted?
3. Which federal awards, pass-through funds, and pending applications could be affected if the certification framework changes?
4. Do our current policies, training materials, and compliance protocols support the statements being certified?
5. Would a final change require updates to subaward communications, contractor expectations, or internal documentation?
6. Do we want to submit a comment focused on definitions, burden, implementation timing, or consistency across agencies?

Understanding The Public Comment Process

This proposal was issued under the Paperwork Reduction Act, which means GSA is seeking public input on a revision to an existing information collection. The notice specifically invites comments on whether the collection is necessary, whether it has practical utility, whether the burden estimate is accurate, how the quality and clarity of the information can be improved, and how burden can be minimized.

That matters because it tells recipients what kind of comment is likely to be most useful. A strong submission does not have to be ideological. It can be practical and implementation-focused. For example, commenters may want to address definitions, timing, interaction with agency-specific award terms, workflow complexity, documentation expectations, or the need for FAQs and technical assistance. Those topics fit squarely within the notice itself. 

The Federal Register notice directs commenters to submit through http://www.regulations.gov, search OMB Control No. 3090-0290, select the “Comment Now” link corresponding to “System for Award Management Registration Requirements for Financial Assistance Recipients,” and include their name, company name, if any, and the information collection title on the attached document. GSA also warns that comments are generally posted publicly without change, including any personal or business confidential information submitted. 

For federal funding recipients, this proposal is worth attention not because every outcome is already known, but because it sits at a critical junction in the federal funding process. The March 30, 2026 deadline gives organizations a limited window to coordinate internally, evaluate operational implications, and decide whether to provide practical feedback while the proposal is still open for comment.