[co-author: Leah Shepherd]
On October 1, 2025, the United States federal government entered a shutdown after congressional lawmakers failed to pass a resolution to continue funding the government. The shutdown will likely cause several disruptions for private employers, including late payments on contracts, disruptions to regulatory processes, and delays in projects. Here are some insights into federal agencies’ shutdown contingency plans.
Quick Hits
- A federal government shutdown began on October 1, 2025, after the U.S. Congress did not reach an agreement to continue to fund federal agencies.
- Federal agencies have issued contingency plans to furlough staff while keeping some essential functions operating.
- While it is unclear how long the shutdown will last, private employers are likely to face disruptions regarding federal contracts, federal investigations or other processes, and federal projects.
Congressional lawmakers had until 11:59 p.m. (EDT) on September 30, 2025, to pass a funding resolution before appropriations for the federal government expired. Hours before the deadline, the White House Office of Management and Budget (OMB) issued a memorandum directing agencies to prepare for a federal government shutdown starting on October 1, 2025.
“[A]ffected agencies should now execute their plans for an orderly shutdown,” OMB Director Russell Vought said in a memorandum. Federal employees were ordered to “report to work for their next regularly scheduled tour of duty to undertake orderly shutdown activities.”
“We will issue another memorandum indicating that government functions should resume once the President has signed a bill providing for appropriations,” Vought said in the memorandum. “Agencies should continue to closely monitor developments, and OMB will provide further guidance as appropriate.”
The federal government shutdown is the first since a shutdown that began in late 2018 and ran for a record thirty-five days into early 2019.
Federal agencies have released contingency plans for operations that include furloughing staff while keeping certain essential operations running, providing insights into which government offices and processes will be disrupted.
Federal Employee Furloughs
While many agencies will be reduced to skeleton crews, some essential employees are not subject to furloughs when the federal government shuts down. For example, those with law enforcement, active military, Coast Guard, border control, emergency response, and air traffic control jobs will continue to work and be paid during any shutdown. In addition, some roles related to public health emergencies, judicial proceedings, medical care at Veterans Affairs facilities, Medicare and Medicaid payments, Social Security benefit payments, and payroll and financial operations for federal agencies will not be furloughed. During past government shutdowns, furloughed employees received back pay for all the furlough days after the government reopened.
Federal Agency Contingency Plans
According to the U.S. Department of Labor’s (DOL) most recent shutdown contingency plan, the agency will pause work by the Bureau of Labor Statistics, Veterans Employment and Training Service, Office of Federal Contract Compliance Programs, Office of Disability Employment Policy, Women’s Bureau, Office of Administrative Law Judges, Administrative Review Board, Benefits Review Board, and Employees’ Compensation Appeals Board.
However, workplace safety agencies, such as the Occupational Safety and Health Administration and the Mine Safety and Health Administration, will continue to respond to imminent threats to human life, investigate child labor violations, conduct mine safety investigations, process disaster Dislocated Worker grant applications, and address legal cases or investigations at risk of being lost due to statute of limitations. Job Corps centers housing students will operate while funds remain available. In total, the DOL expects 3,141 employees to continue working during the shutdown out of 12,916 employees on board before the shutdown.
The U.S. Equal Employment Opportunity Commission (EEOC) will also significantly reduce its workforce. According to the agency’s shutdown contingency plan, the EEOC plans to keep at least 128 employees while furloughing the rest of its approximately 1,814 employees. These employees will ensure that new charges are docketed, continue to litigate cases where a continuance has not been granted, and preserve the “security, integrity, and viability of EEOC information systems.” The EEOC will not begin new investigations, conduct mediations or hearings, or process Freedom of Information Act (FOIA) requests during the shutdown.
The National Labor Relations Board (NLRB) will discontinue case handling, outreach and public affairs during the government shutdown, according to its contingency plan. The NLRB will continue necessary court actions, the Office of Inspector general hotline, and an emergency contact. The agency plans to have 1,247 employees continue working, while 1,237 will be furloughed.
Meanwhile, the Social Security Administration (SSA) plans to furlough 6,197 employees and have 45,628 employees work during the shutdown, including workers handling benefits applications, information technology support, and fraud prevention activities, according to its contingency plan.
Additionally, the shutdown will likely impact certain immigration-related services and operations, such as the E-Verify system and the approval of certain work visas.
Next Steps
The federal government shutdown is likely to significantly impact private employers across the country. Depending on how long the shutdown lasts, federal agencies may experience backlogs in work, such as rulemaking or conducting non-priority workplace safety inspections. Private employers could see longer wait times for certain government services and delays in government investigations or processes. However, this is a quickly moving issue, and it is unclear how long the shutdown will last. Employers may want to stay updated on the latest developments.
