Last week, U.S. Secretary of Labor Lori Chavez-DeRemer issued Order 08-2025 and the Office of Federal Contract Compliance Programs (OFCCP) issued a Bulletin explaining the Secretary’s Order. Importantly for federal contractors, “OFCCP will be exercising its discretion to administratively close all pending compliance reviews and will take no further action related to the scheduling list
2024 EEO-1 Data Collection Opens
As of yesterday—May 20, 2025—EEO-1 data collection is open. The deadline to file the 2024 EEO-1 Component 1 report is June 24, 2025. The EEOC stated there will be no extensions, so covered employers should act promptly to file their reports. For detailed information on the EEOC’s substantive filing requirements, employers may refer to the
EEO-1 Component 1 Reporting Updates
Edited May 20, 2025
Last month, the Equal Employment Opportunity Commission (“EEOC”) submitted a proposed 2024 EEO-1 instruction booklet to the Office of Management and Budget. If the proposal is approved, the EEO-1 reporting period will begin on May 20, 2025 and run through June 24, 2025. As employers prepare to file their 2024 EEO-1
Executive Order Seeks to Repeal Disparate Impact Liability
On April 23, 2025, President Trump issued a new executive order aimed at repealing disparate impact liability. The order, titled “Restoring Equality of Opportunity and Meritocracy” (https://www.whitehouse.gov/presidential-actions/2025/04/restoring-equality-of-opportunity-and-meritocracy/), frames equal treatment under the law as “equality of opportunity, not equal outcomes.”
Disparate impact is a theory of liability that grew out of equal employment
Federal Court of Appeals Stays Preliminary Injunction on Trump DEI Executive Orders
On Friday, March 14, 2025, the Fourth Circuit Court of Appeals lifted a preliminary injunction on President Trump’s Executive Orders regarding DEI. In concurring opinions, the judges expressed varying levels of support for employers’ DEI initiatives. However, the appellate panel agreed that the district court’s pre-implementation preliminary injunction was premature, and the Fourth Circuit stayed
Trump Executive Order Significantly Limits Longstanding DEI Requirements for Federal Contractors
On his second day in office, January 21, 2025, President Trump issued an Executive Order “Ending Illegal Discrimination and Restoring Merit-Based Opportunity.” This Executive Order reverses roughly 60 years of federal policy and leaves many employers with questions about the future of diversity, equity, and inclusion (DEI) policies and affirmative action programs (AAPs). Federal contractors
Federal Court Grants Preliminary Injunction to Stop OFCCP Enforcement Action
On October 30, 2024, a Texas federal court issued a preliminary injunction to halt an enforcement action by the Office of Federal Contract Compliance Programs (OFCCP) against ABM Industry Groups, LLC, a federal contractor. This case, while directly impacting only one contractor, could have significant implications for the broader landscape of OFCCP enforcement through Administrative
Federal Contractors – Reminder to Certify Affirmative Action Programs
Federal contractors and subcontractors must certify the status of their Affirmative Action Programs (AAPs) to the Office of Federal Contract Compliance Programs (OFCCP) by July 1, 2024.
Who Must Certify?
The certification requirement applies to all federal supply and service contractors and subcontractors (at any tier) that meet jurisdictional thresholds of 50 or more