Part 2: Before You Certify, Verify

A Pragmatic Compliance Framework for Federal Contractors The IBM and Deloitte settlements do not mean that contractors should stop conducting outreach, reviewing workforce data, or working to ensure equal employment opportunity. They demonstrate the importance of distinguishing between two very different activities: Using workforce data to identify and remove possible barriers; and Using protected characteristics…
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OFCCP Is Fully Funded for 2026: Part 2 – What Federal Contractors Should Do Now: Best Practices, Liabilities, and How to Avoid Risk in 2026

Even if OFCCP remains quieter than in past years, federal contractors should not interpret that as a compliance “pause.” In 2026, the smartest strategy is quiet preparation. Contractors should assume: compliance obligations still exist enforcement can resume quickly data and transparency will drive scrutiny complaints and whistleblowers will trigger investigations The Liability Federal Contractors Can…
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