President Trump’s revocation E.O. requires agencies to “promptly move to rescind any orders, rules, regulations, guidelines, programs, or policies implementing or enforcing Executive Order 13495.” It further requires the Secretary of Labor to immediately terminate any investigations or compliance actions based on E.O. 13495.

Many contractors may welcome the revocation, because the 10-day offer period for incumbent service employees imposed by E.O. 13495 complicated contract transitions and effectively prohibited successor contractors from hiring employees they deemed more qualified than the existing employees. Other than enforcement actions, however, contractors should be aware that the revocation of E.O. 13495 must still go through the formal rulemaking process. Thus, this new E.O. will not be fully effective until a final rule is issued which implements the President’s revocation.