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DEI Under Pressure – What Organizations Need to Know Before May 21

As part of a now well-known January 2025 executive order aimed at rolling back DEI initiatives, the Trump administration has asked every federal agency to identify nine organizations—including companies, universities, and nonprofits— each believes is in violation of federal civil rights or contracting rules because of DEI-related practices. These lists are due to the White House by May 21, 2025, and are expected to inform future investigations, funding decisions, and public enforcement. Many organizations have already taken action to modify policies in reaction to the EO; however, with 440 agencies listed in the Federal Register, the directive could result in up to 3,960 organizations being named.

To help your organization prepare for this upcoming deadline, FGS Global created a memo explaining key themes and risk signals that have emerged across sectors, drawn from our analysis of public disclosures, agency actions, and media narratives.



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