What This Means in Practice: A Compliance Checklist

“VERIFY BEFORE YOU CERTIFY” — 3-MINUTE BRIEF, PART 3 OF 4 Parts 1–2 covered the rules and the three certification layers. This brief: what to actually do about it. Recap: Contractors now certify nondiscrimination through SAM.gov representations, the EO 14173 certification embedded in each contract, and FAR 52.222-90. Here’s what stays in force separately, and…
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FEDERAL CONTRACTOR COMPLIANCE ALERT: $25 Million Accenture Settlement – Civil Rights Noncompliance Can Become False Claims Act Exposure

Federal contractors should take notice. On September 14, 2026, the U.S. Department of Justice announced that Accenture Federal Services, Accenture plc, and Accenture LLP agreed to pay $25 million to resolve allegations that they violated the False Claims Act (FCA) by failing to comply with nondiscrimination requirements in federal contracts while allegedly discriminating in employment…
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The New Rules: How Federal Contractor Certification Changed Twice in 18 Months

“VERIFY BEFORE YOU CERTIFY” — 3-MINUTE BRIEF, PART 1 OF 4 A quick-read series on how federal contractors certify nondiscrimination today. This brief: what changed, and why. Federal contractors don’t certify nondiscrimination through a single document anymore. As of 2026, compliance runs through three separate layers — and this series breaks down exactly what each…
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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 2 – EEOC Enforcement: The Risk Has Not Gone Away

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,…
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