October 30, 2025
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Category: Affirmative Action and DEI

CWC Recommends OFCCP Retain Form CC-305 On A Voluntary Basis

The Center for Workplace Compliance, our affiliated nonprofit membership association, has filed comments with the Office of Federal Contract Compliance Programs urging it to consider alternatives to its proposed elimination of Form CC-305. Federal contractors use the Voluntary Self-Identification of Disability Form to solicit the disability status of their job applicants and employees. OFCCP recently proposed eliminating the requirement for...
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October 29, 2025
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Category: Compliance Reporting and Recordkeeping

California Updates Pay Data Reporting Requirements

California recently amended its pay data reporting obligations, which require covered employers to submit employee and labor contractor pay data reports annually to the Civil Rights Department (CRD). Under the amendment, starting in 2026: (1) employers must store demographic data separately from personnel records, and (2) penalties for failing to file pay data reports will become mandatory if CRD requests them. The...
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August 12, 2025
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Category: Compliance Reporting and Recordkeeping

DOL Ordered To Release EEO-1 Type 2 Contractor Data

A federal appeals court has ordered the Labor Department to release EEO-1 Type 2 consolidated data from the years 2016 to 2020 submitted by contractors that objected to a 2022 Freedom of Information Act request filed by the Center for Investigative Reporting. A panel of the U.S. Court of Appeals for the Ninth Circuit rejected DOL’s argument that headcount and...
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July 01, 2025
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Category: Affirmative Action and Diversity

OFCCP Proposes Eliminating Disability Self-Identification and Analysis Requirements

The Office of Federal Contract Compliance Programs is proposing to eliminate longstanding disability compliance requirements, including self-identification, utilization analyses, and applicant tracking. If approved, OFCCP’s two Notices of Proposed Rulemaking (NPRM) would modify agency regulations that implement the nondiscrimination and affirmative action requirements of Section 503 of the Rehabilitation Act (Section 503) and Section 4212 of the Vietnam Era Veterans...
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June 19, 2025
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Category: Affirmative Action and Diversity

CWC’s Guide to Minnesota State Contractor Equal Employment Opportunity Requirements

The Center for Workplace Compliance (CWC), our affiliated nonprofit membership association, has updated a resource that can help its members understand the equal employment opportunity obligations that Minnesota imposes on state contractors. These obligations are contained in documents published by the state’s Department of Human Rights (MDHR), including guidance, required forms, and templates for contractors submitting EEO compliance plans. Following...
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January 15, 2025
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Category: Compensation

Massachusetts Publishes Filing Details for February 1st EEO-1 Reporting Requirement

Massachusetts has issued FAQs explaining employers’ obligation to report workforce data under the state’s new Salary Range Transparency Act. Under the law, employers with 100 or more employees in Massachusetts must submit a copy of their most recent EEO-1 Report to the state annually by February 1 (or the next business day). This year they will be due February 3. The FAQs explain...
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January 15, 2025
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Category: Agency Enforcement

EEOC Revises Rule Governing EEO Reporting Exemptions

The EEOC issued a final rule January 10, 2025, revising its regulations governing hardship exemptions from annual EEO-1 reporting.   To be exempt from EEO reporting requirements, an employer must show undue hardship. Previously, EEOC Commissioners voted on exemption applications. Now, however, the Chief Data Officer will process applications. Under the new rule, an exemption is more likely to be granted when: The filer...
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December 03, 2024
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Category: Compliance Reporting and Recordkeeping

OFCCP Construction Contractor Utilization Report Due April 2025 (and Every Month Thereafter)

Federal construction contractors and subcontractors must begin filing their monthly CC-257 forms April 15, 2025, the Labor Department’s Office of Federal Contract Compliance Programs announced. Employers that have a federal construction contract or subcontract, or a contract in which federal funds pay for construction work worth more than $10,000, must submit a Monthly Employment Utilization Report (CC-257) to OFCCP on...
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November 07, 2024
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Category: Compliance Reporting and Recordkeeping

Religious Groups Seek To Block FCC Demographic Data Collection Similar to EEO-1 Report

A group of religious broadcasters has asked a federal appeals court to block the Federal Communications Commission (FCC) from collecting race and ethnicity data from broadcasters. The court’s ruling could have implications for similar data collections like the EEO-1 Report. Earlier this year, the Federal Communications Commission (FCC) voted to resume collecting race and ethnicity data from broadcasters, a practice...
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October 31, 2024
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Category: Compliance Reporting and Recordkeeping

New FOIA Requests Seek Contractor EEO-1 Data From 2021

OFCCP will release the EEO-1 Type 2 Reports for thousands of contractors for the 2021 filing year unless the contractors file a written objection with OFCCP by December 9, the agency announced October 29, 2023. The release will occur in response to Freedom of Information Act requests from the University of Utah and a non-profit organization named As You Sow. The...
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