News & Analysis as of

Office of Federal Contract Compliance Programs Federal Contractors Disclosure Requirements

McGlinchey Stafford

9th Circuit: Federal Contractor Workforce Reports Not Exempt Under FOIA

McGlinchey Stafford on

On July 30, the 9th Circuit Court of Appeals settled a long-standing debate between federal contractors and journalists when it ruled on Center for Investigative Reporting v. United States Department of Labor. Their decision...more

Proskauer - Government Contractor Compliance...

Ninth Circuit Orders Release of Federal Contractor EEO-1 Reports

On July 30, 2025, the U.S. Court of Appeals for the Ninth Circuit ruled that the Department of Labor (“DOL”) must disclose federal contractor EEO-1 Reports requested by the Center for Investigative Reporting (“CIR”). The...more

Jackson Lewis P.C.

Ninth Circuit Affirms Disclosure of EEO-1 Reports Under FOIA

Jackson Lewis P.C. on

On July 30, 2025, the Ninth Circuit Court of Appeals upheld a district court order requiring the U.S. Department of Labor (DOL) to release EEO-1 reports previously withheld in response to Freedom of Information Act (FOIA)...more

Constangy, Brooks, Smith & Prophete, LLP

Appellate court orders disclosure of contractors’ EEO-1 Reports

The Ninth Circuit rules that FOIA does not protect data from disclosure.  As we previously reported, the Center for Investigative Reporting and its reporter Will Evans are battling the U.S. Department of Labor over its...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

Ninth Circuit Orders Disclosure of Federal Contractors’ 2016–2020 Consolidated EEO-1 Data

In a ruling significant to federal contractors and government transparency advocates alike, the U.S. Court of Appeals for the Ninth Circuit has affirmed a district court order requiring the U.S. Department of Labor (DOL) to...more

Proskauer - Government Contractor Compliance...

OFCCP Seeks Voluntary Disclosures from Federal Contractors on EO 14173 Compliance

On June 27, 2025, Office of Federal Contract Compliance Programs (“OFCCP”) Director Catherine Eschbach issued a letter announcing that OFCCP is “providing all federal contractors withthe opportunity to volunteer informationin...more

Bond Schoeneck & King PLLC

OFCCP Invites Federal Contractors to Voluntarily Disclose Efforts to Wind Down Executive Order 11246 Obligations

July 2, 2025 By: Christa Richer Cook On June 27, 2025, the Office of Federal Contract Compliance Programs (OFCCP) announced in a letter to federal contractors that they were invited to share information regarding their...more

Constangy, Brooks, Smith & Prophete, LLP

OFCCP invites contractors to disclose efforts to wrap up EO 11246 compliance

File under “thanks, but no thanks.” In an open letter to contractors, Catherine Eschbach, Director of the Office of Federal Contract Compliance Programs, offers contractors the opportunity to explain how they have wound...more

Berkshire

OFCCP Requests Voluntary Reporting of EO 14173 Compliance

Berkshire on

Earlier today, OFCCP Director Catherine Eschbach sent an email letter to federal contractors offering the “opportunity to provide information about their efforts to wind down compliance with the EO 11246 regulatory scheme and...more

Jackson Lewis P.C.

OFCCP Invites Voluntary Disclosures from Federal Contractors Regarding Executive Order 14173

Jackson Lewis P.C. on

In a letter dated June 27, 2025, sent to federal contractors and posted on its website, the Office of Federal Contract Compliance Programs (OFCCP) announced it is providing federal contractors the option to voluntarily submit...more

Verrill

Deadline Approaching for Federal Contractors to Object to Disclosure of EEO-1 Reports

Verrill on

Federal contractors have until December 10, 2024, at 11:59 p.m. to file written objections to the disclosure of their EEO-1 Type 2 Consolidated Reports in response to a recent Freedom of Information Act (FOIA) request. This...more

Perkins Coie

OFCCP Set To Release Contractors' EEO-1 Reports to FOIA Requestors

Perkins Coie on

The U.S. Department of Labor’s Office of Federal Contracting Compliance Programs (OFCCP) may release federal contractors’ Type 2 Consolidated Employer Information Report (aka Standard Form 100) data (EEO-1 Report) in response...more

K&L Gates LLP

Proposed Rule by the Federal Acquisition Regulatory Council Would Ban the Use of Salary History Data by Federal Contractors and...

K&L Gates LLP on

On 29 January 2024, the Federal Acquisition Regulatory Council (FAR Council) issued a Notice of Proposed Rule Making (NPRM) that would prohibit federal contractors and subcontractors from seeking and considering information...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

OFCCP Proposes Changes to Construction Contractor Scheduling Letter and Contract Award Notification Requirement Form

On February 26, 2024, the Office of Federal Contract Compliance Programs (OFCCP) published a notice in the Federal Register, seeking to renew and make changes to its construction compliance review scheduling letter and...more

Jackson Lewis P.C.

OFCCP to Appeal Adverse EEO-1 Report Disclosure Order

Jackson Lewis P.C. on

As previously reported, in December 2023, the U.S. Department of Labor, Office of Federal Contract Compliance Programs (OFCCP) was ordered to release the EEO-1 reports of federal contractors it had withheld from production in...more

Seyfarth Shaw LLP

Proposed Rule That Will Require Federal Contractors and Subcontractors to Disclose Compensation Data in Job Postings and Prohibit...

Seyfarth Shaw LLP on

Seyfarth Synopsis: Twenty-four hours after the White House marked the 15th Anniversary of the Lilly Ledbetter Fair Pay Act, by announcing a set of actions designed to support equal pay principles for workers of federal...more

Proskauer - Government Contractor Compliance...

Biden Administration Proposes New Pay Inquiry and Transparency Requirements For Contractors

On January 29, 2024, the 15th anniversary of the enactment of the Lilly Ledbetter Fair Pay Act, the Biden Administration announced that it would be taking new actions to implement the Executive Order on Advancing Economy,...more

Proskauer - Government Contractor Compliance...

Court Orders Release of Contractor EEO-1 Reports

On December 22, 2023, a court in the Northern District of California ordered the disclosure of EEO-1 Reports filed by federal contractors and subcontractors (“Contractors”) between 2016 and 2020 in the case, Center for...more

Polsinelli

Federal Court Rejects Objections and Orders OFCCP to Disclose EEO-1 Reports

Polsinelli on

Despite objections by thousands of employers and its own continuing review of records, the OFCCP has been ordered by a federal court to produce all EEO-1 Type 2 reports of federal prime contractors and first-tier...more

Poyner Spruill LLP

Employers with Federal Contracts Should Take Affirmative Steps to Maintain Confidentiality of Pay Data Submitted via EEO-1 Survey

Poyner Spruill LLP on

As discussed in our prior alert, employers are now required to submit additional information to supplement EEO-1 reports. The deadline to submit this new information – which will include employee pay data (referred to by the...more

Snell & Wilmer

Government Contracting and Executive Orders Under a Trump Administration - Part One

Snell & Wilmer on

With President-elect Trump’s victory, what is the future of President Barack Obama’s executive orders? As President Obama’s administration winds down, the Department of Labor has finalized regulations implementing several...more

Littler

Taking a Closer Look at the New Federal Contractor "Blacklisting" Obligations

Littler on

On August 25, 2016, the Federal Acquisition Regulatory (FAR) Council published in the Federal Register its highly anticipated Final Rule regarding the so-called "blacklisting" procedures for federal contractors President...more

Cozen O'Connor

Federal Contractors Must Report All Federal Labor Law Violations

Cozen O'Connor on

Federal contractors and subcontractors soon will be required to report all federal “labor law violations” to the government, for review by contracting officers. Here’s what you need to know about this sweeping new...more

Littler

Final Blacklisting and Contractor Paid Sick Leave Rules Slated for Late Summer Publication, According to Spring Regulatory Agenda

Littler on

Although this election season may feel endless, there are only six more months until voters decide the next president and members of Congress. Within this window, federal agencies are scrambling to finalize rules before the...more

Proskauer - Government Contractor Compliance...

OFCCP Seeks Final Approval Of Its Pay Transparency Regulations From OMB

OFCCP recently sent its proposed final regulations implementing Executive Order 13665 (the “Order”) to the Office of Management and Budget (“OMB”) for final approval. The Order, among other things, mandates that federal...more

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