What the executive orders actually said
On January 20, 2025, President Trump signed two executive orders — "Ending Illegal Discrimination and Restoring Merit-Based Opportunity" and "Ending Radical and Wasteful Government DEI Programs and Preferencing" — that together directed federal agencies to terminate DEI offices, end DEI-related training contracts, and revoke the policy underpinning affirmative action in federal contracting dating to Executive Order 11246 (originally signed by Lyndon Johnson in 1965).
The orders instructed agency heads to enforce existing anti-discrimination law and required federal contractors to certify they do not operate "unlawful DEI programs." A follow-on executive order in February 2025 extended pressure to private companies: the Equal Employment Opportunity Commission and the Department of Justice were directed to investigate corporate DEI programs.
What the orders did not do: touch the Small Business Act, the National Defense Authorization Act, or any of the statutes that authorize federal small-business set-asides and subcontracting plan requirements. Those are federal law. An executive order cannot repeal a statute.
Federal set-asides: statutory, not discretionary
The SBA's core certification programs and the set-aside contracting framework they enable are authorized by statute, not executive policy. The relevant laws have been in place for decades and were not modified by any 2025 executive order.
- 8(a) Business Development Program: authorized by Section 8(a) of the Small Business Act (15 U.S.C. § 637(a)). Targets socially and economically disadvantaged small businesses. FY2024 awards exceeded $30 billion.
- Women-Owned Small Business (WOSB) Federal Contracting Program: authorized by the Small Business Reauthorization Act of 2000, codified at 15 U.S.C. § 637(m). Annual WOSB set-aside awards run roughly $28–30 billion.
- HUBZone Program: authorized by the HUBZone Act of 1997 (15 U.S.C. § 657a). Targets firms in historically underutilized business zones.
- Service-Disabled Veteran-Owned Small Business (SDVOSB): authorized by the Veterans Benefits Act of 2003 (15 U.S.C. § 657f).
Taken together, federal small-business set-aside contracting has exceeded $96 billion annually in recent fiscal years. The statutory floor for federal small-business prime contracting is 23% of eligible spending. Agencies that miss their goals face scrutiny from the SBA and congressional oversight committees.
Subcontracting plan requirements — where large prime contractors must set goals for small and diverse subcontractors on contracts exceeding $750,000 — are also statutory, under 15 U.S.C. § 637(d). That requirement did not change.
If you hold an 8(a), WOSB, HUBZone, or SDVOSB certification, or are pursuing one, the opportunity structure is intact.
What did change at the corporate level
This is where the picture is more complicated.
Voluntary corporate supplier diversity programs — the kind run by Fortune 500 procurement teams under "supplier diversity" or "minority business development" banners — are not legally required. They exist because companies chose to build them, often in response to pressure from shareholders, institutional investors, and their own workforce. When that pressure shifted, some programs followed.
Ford Motor Company dismantled its formal supplier diversity function in early 2025 and folded remaining work into general procurement. Harley-Davidson dissolved its supplier diversity office in late 2024, before the executive orders, as part of a broader DEI retreat. John Deere, Molson Coors, and Tractor Supply each announced reductions to DEI-adjacent programs in 2024 and continued contracting them through 2025. Several large financial institutions, including Goldman Sachs and Citigroup, quietly removed supplier diversity spend targets from public reporting.
The terminology shift is real. Companies that maintained programs are increasingly describing them in terms of "small business development," "economic impact," "supply chain resilience," and "local sourcing." The underlying procurement activity may be the same. The public-facing framing changed because the legal and reputational calculus changed.
Which companies held the line
Not every large buyer retreated.
Costco put its DEI stance to a shareholder vote in January 2025 and won. The board recommended against a proposal to eliminate DEI programs; shareholders voted with the board by a wide margin. Costco's supplier development program, which includes diversity sourcing, remains active.
Apple published a letter from CEO Tim Cook in February 2025 reaffirming the company's commitment to inclusion and supplier diversity programs. Apple's Supplier Responsibility reports still include diversity spend metrics.
Microsoft's supplier diversity program continues to operate with published spend commitments. Microsoft has not altered its public targets.
JPMorgan Chase, despite broader sector retreats, maintained its supplier diversity office and continued publishing spend data through 2025. General Motors likewise kept its supplier diversity function intact, framing it internally as a supply chain competitiveness initiative.
The clearest pattern: companies with embedded supplier development infrastructure — where diverse suppliers are part of category strategies, not a separate diversity function — were less likely to make visible cuts. Companies where supplier diversity lived as a standalone DEI-adjacent unit were more exposed.
NMSDC and WBENC: still intact
The National Minority Supplier Development Council and the Women's Business Enterprise National Council are private membership organizations. Neither is a federal agency. Their certifications — the MBE (Minority Business Enterprise) credential issued by NMSDC regional councils, and the WBE credential issued by WBENC regional partner organizations — are not affected by federal executive orders.
Both organizations report that corporate member retention held through 2025, though some members reduced their financial commitments to regional council events and sponsorships. Certification demand from diverse suppliers increased in some regions, as business owners sought credentials that would qualify them across both federal and private-sector opportunities.
NMSDC has approximately 1,750 corporate members and a database of roughly 15,000 certified MBEs. WBENC has approximately 500 corporate members and more than 17,000 certified WBEs. Those numbers did not collapse in 2025.
Other certification bodies — NGLCC (LGBTQ+-owned), Disability:IN (disability-owned), NaVOBA (veteran-owned, private-sector track) — similarly operate independently of federal DEI policy.
The compliance case for primes and their subcontractors
If you are a prime contractor on a federal contract above $750,000 (or $1.5 million for construction), you are legally required to submit a subcontracting plan with goals for small business, small disadvantaged business, women-owned small business, HUBZone, SDVOSB, and veteran-owned small business participation. That plan is evaluated during source selection and tracked through contract performance.
The SBA's Commercial Market Representatives (CMRs) review subcontracting plans. Failure to make good-faith efforts to meet goals can trigger liquidated damages under the Federal Acquisition Regulation (FAR 52.219-16) and can affect a prime's past-performance record.
This means prime contractors have a statutory reason to source from certified diverse firms, regardless of whether they have a branded supplier diversity program or call it something else. For subcontractors, holding SBA certifications is not about participating in a voluntary initiative. It is about being eligible for a specific category of contract awards that is backed by law.
Practical implications if you're a diverse business owner
If your target market is federal contracting: the framework is unchanged. Pursue and maintain your SBA certifications. The agencies buying goods and services have the same small-business goals they had in 2024. Federal contracting officers need to hit their numbers.
If your target market is corporate procurement: expect more variation. Some buyers have reduced or eliminated formal diversity supplier programs. Others maintained them under different names. Ask procurement contacts directly what criteria they use for supplier qualification. A certification from NMSDC, WBENC, or another recognized body still signals legitimacy and gets you into the database where sourcing teams look.
On terminology: when presenting to corporate buyers in 2025 and 2026, leading with "economic impact" and "supply chain resilience" framing is not compromise — it is meeting buyers where they are. The underlying value proposition (access to qualified suppliers you might not find through incumbent networks) did not change. The language did.
On pipeline: the companies that reduced voluntary programs were concentrated in retail, consumer goods, and financial services. Defense, aerospace, technology, and healthcare primes still have contractual subcontracting obligations that require them to source certified firms.
The bottom line
Federal set-aside contracting, the subcontracting plan regime, and SBA certification programs are grounded in statute. Executive orders have not touched them. More than $96 billion in annual federal set-aside spend is still on the table.
Voluntary corporate programs took real damage. Some are gone. Others rebranded. A meaningful number of major buyers — including Costco, Apple, Microsoft, JPMorgan, and GM — held their programs intact.
The companies still buying from certified diverse suppliers outnumber the ones that stopped. The pipeline contracted in some sectors. It did not disappear.
Get certified. Work the federal pipeline. When approaching corporate buyers, ask what they call their program now and how they source. The door is narrower in some rooms. It is still open.
