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 – 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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OMB Approves Renewal of Form CC-305: Federal Contractors Must Continue Collecting Voluntary Disability Self-Identification Information

On July 16, 2026, the Office of Management and Budget (OMB) has approved the continued use of Form CC-305 (Voluntary Self-Identification of Disability), reaffirming that covered federal contractors remain subject to the disability self-identification requirements under Section 503 of the Rehabilitation Act. The approved form is available on the U.S. Department of Labor’s website. OFCCP…
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Part 2: Workforce Diagnostic Analytics, The Missing Risk Management Tool

The most important lesson from recent DOJ investigations is not that discrimination exists. The most important lesson is that the government is increasingly using data, statistical evidence, and outcome analyses to identify potential violations. Federal contractors should be doing the same. What Are Workforce Diagnostic Analytics? Workforce diagnostic analytics are statistical and compliance analyses designed…
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Part 1 – Federal Contractors: Prepare for the Next Wave of Audits

EO 14398 and FAR 52.222-90 Signal a Major Shift in Federal Enforcement The federal contractor compliance landscape is undergoing one of its most significant transformations in decades. For years, contractors largely associated compliance oversight with affirmative action plans, OFCCP desk audits, and technical reporting obligations. Today, however, the federal government appears to be expanding its…
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