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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PART 1 – EO 14398 & FAR 52.222-90: Nondiscrimination Enters the Federal Procurement Process

The federal contractor nondiscrimination landscape has evolved significantly. Following recent federal procurement changes associated with Executive Orders 14173 and 14398, Addressing DEI Discrimination by Federal Contractors, the FAR Council introduced FAR 52.222-90, Addressing DEI Discrimination by Federal Contractors (APR 2026). The significance for federal contractors is substantial: nondiscrimination requirements are now being incorporated directly into…
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Federal Contractor Minimum Wage Mandate Revoked: What You Need to Know

On March 14, 2025, President Donald Trump issued an executive order rescinding the federal contractor minimum wage mandate, a policy originally established under the Biden administration. This decision removes the requirement for federal contractors to pay workers at least $17.75 per hour, allowing wages to be set according to the federal minimum wage ($7.25 per…
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