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Breaking Down the Proposed Salary History and Pay Transparency Requirements for Federal Contractors

On January 31, 2024, several U.S. government agencies released proposals and guidance aimed at imposing new pay transparency and salary history requirements upon federal government contractors and subcontractors. These...more

OFCCP Walks Back Portions of Its Controversial Pay Equity Directive, But Contractors Must Still Focus on Proactively Ensuring...

In March 2022, we reported on a controversial directive issued by the Office of Federal Contract Compliance Programs (OFCCP) that appeared to assert, for the first time, that federal contractors and subcontractors are...more

Ban on Salary History Inquiries to Expand to Federal Contractors

The emerging trend of laws banning inquiries into salary history and promoting pay transparency will soon expand to federal contractors.  On March 15, 2022, President Biden issued an Executive Order titled “Executive Order on...more

OFCCP Issues New Directive Requiring Pay Equity Audits

On March 15, 2022, the Office of Federal Contract Compliance Programs (OFCCP) issued its first directive of the Biden Administration to address the requirement that federal government contractors and subcontractors perform...more

OFCCP May Use EEO-1 Data Reported By Employers in Support of Enforcement Efforts

On September 1, 2021, the Office of Federal Contract Compliance Programs (OFCCP) announced that it would “evaluate” using compensation data reported by federal contractors in annual EEO-1 filings to guide its enforcement...more

Biden OFCCP Director Appointment Signals That More Pay Equity Enforcement is on the Horizon for Federal Contractors

The new Biden administration wasted no time implementing changes at the Office of Federal Contract Compliance Programs (OFCCP).  On January 20, 2021, the day of President Biden’s inauguration, the administration moved...more

After Record Settlements in 2020, Contractors Should Expect More Pay Equity Enforcement Under Biden

Come Jan. 20, former Vice President Joe Biden will be inaugurated as the U.S.' 46th president. In the run-up to the election, the Biden campaign focused on pay equity issues and closing the wage gap as part of its platform to...more

EEOC Not Requiring Pay Data with EEO-1 Submissions for Now, But Uncertainty Remains

On March 4, 2019 Judge Chutkan of the U.S. District Court for the District of Columbia issued a ruling that immediately reinstated the EEO-1 pay data reporting requirement....more

Employers Must Prep for New EEOC Data Reporting Rule

Employers who thought that they had received a respite from the U.S. Equal Employment Opportunity Commission’s proposed requirement to report information about employees' pay and hours worked when submitting their annual...more

EEOC Announces Deadlines (For Now) for Submission of 2018 EEO-1 Data

On February 1, 2019, the Equal Employment Opportunity Commission (“EEOC”) announced that it would postpone the opening of the submission period for EEO-1 survey responses until “early March 2019” and extend the deadline for...more

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