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Out with the DUNS, In with the UEI: GSA Announces Transition Deadline for April 2022

Client Alert | 1 min read | 08.10.21

On July 28, 2021, the GSA shared a blog post on its outreach site, GSA Interact, announcing the final transition deadline of April 4, 2022, from using the 9-digit Data Universal Numbering System (DUNS number) to the new 12-digit alphanumeric Unique Entity ID (UEI) codes in SAM.gov.  On that date, no new DUNS numbers will be issued, and only the new UEI will be provided in SAM.gov data and reports.  All entities already registered in SAM.gov have been assigned a UEI, which is viewable in the entity registration record in SAM.gov.  Contractors should prepare their own internal systems and processes to accept the new UEI numbers and to stop using the DUNS number for federal awards processes by April 2022.

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Client Alert | 7 min read | 12.17.25

CARB Proposes Regulations Implementing California GHG Emissions and Climate-Related Financial Risk Reporting Laws

After hosting a series of workshops and issuing multiple rounds of materials, including enforcement notices, checklists, templates, and other guidance, the California Air Resources Board (CARB) has proposed regulations to implement the Climate Corporate Data Accountability Act (SB 253) and the Climate-Related Financial Risk Act (SB 261) (both as amended by SB 219), which require large U.S.-based businesses operating in California to disclose greenhouse gas (GHG) emissions and climate-related risks. CARB also published a Notice of Public Hearing and an Initial Statement of Reasons along with the proposed regulations. While CARB’s final rules were statutorily required to be promulgated by July 1, 2025, these are still just proposals. CARB’s proposed rules largely track earlier guidance regarding how CARB intends to define compliance obligations, exemptions, and key deadlines, and establish fee programs to fund regulatory operations....