The revocation of Executive Order 11246 significantly changed the federal contractor compliance landscape, but it did not eliminate employers’ underlying nondiscrimination obligations or enforcement risk.
While OFCCP has ceased investigative and enforcement activity under the former EO 11246 program, the EEOC continues to actively enforce Title VII, including cases involving race discrimination in hiring, promotions, compensation, work assignments, harassment, terminations and other terms and conditions of employment.
Recent enforcement actions demonstrate that the financial consequences can be significant.
Recent EEOC Race Discrimination Settlements
Since August 2025, the EEOC has announced monetary resolutions involving allegations or findings of race discrimination, including:
R&R Janitorial, Painting & Building Services — $1.25 Million The federal contractor agreed to settle an EEOC lawsuit alleging race and national-origin discrimination involving Hispanic janitorial workers.
Planned Parenthood of Illinois — $500,000 The EEOC resolved a DEI-related race discrimination investigation involving allegations of race-based segregation, harassment, and disparate treatment in terms, conditions and privileges of employment.
Sunnybrook Union — $110,000 The EEOC alleged that a Black employee was denied a promotion because of his race.
Metro Eighteen — $70,098 The settlement resolved allegations involving racial harassment and retaliation against a Black employee.
Epiq Food Hall — $54,000 The company resolved an EEOC racial harassment lawsuit involving a Black manager.
These cases reinforce an important point:
The enforcement framework has changed. The risk of discrimination claims has not.
Federal contractors now operate in an environment where EEOC Title VII enforcement continues while EO 14398 and FAR 52.222-90 add a contractual nondiscrimination dimension to federal procurement.
Potential exposure can therefore arise from multiple directions:
- EEOC Enforcement
- Employee Complaints
- Federal Contract Requirements
- Contracting Officer Inquiries
- False Claims Act Considerations
- Suspension or Debarment
If you’re ready to strengthen your compliance and equity efforts, contact us today to learn how we can support your EEO and non-discrimination goals.