On April 20, 2026, the Office of Federal Procurement Policy (”OFPP”) and the FAR Council released updated model deviations for FAR Parts 9, 12, 22, and 52 to implement Executive Order (”EO”) 14398, Addressing DEI Discrimination by Federal Contractors.
These updates significantly expand the government’s enforcement toolkit, making compliance contractually required and specifically enforceable through contractual remedies, FAR Part 9 suspension and debarment, and the False Claims Act.
What changed: The model deviation updates
FAR Part 9 — Debarment and suspension
Perhaps the most significant development in the April 20 updates is the addition of DEI noncompliance as an express basis for debarment and suspension.
FAR Subpart 9.4 (debarment, suspension, and ineligibility) has been updated to provide that a contractor’s failure to comply with the requirements of new clause 52.222-9 may serve as a basis for both debarment under FAR 9.406-2(b)(1)(viii) and suspension under FAR 9.407-2(a)(11).
By explicitly naming DEI noncompliance as a ground for debarment and suspension — remedies that can effectively bar a company from the federal marketplace — the government has removed any ambiguity about its intent to enforce compliance aggressively.
Read more here.