“VERIFY BEFORE YOU CERTIFY” — 3-MINUTE BRIEF, PART 4 OF 4
The final brief in this series: what to have audit ready before a request ever arrives.
Recap: FAR 52.222-90 requires contractors to furnish “all information and reports, including providing access to books, records, and accounts, as required by the Contracting Officer.” No agency has published a standardized checklist. Based on what the clause prohibits and how similar investigations have historically been conducted, here’s what to have ready.
Hiring, Promotion & Termination Records
- Applicant flow logs and interview scorecards for open positions
- Records showing who was selected vs. not selected, and the stated rationale
- Promotion and succession-planning documentation, including any candidate lists or slates
- Termination and reduction-in-force records, including selection criteria used
Compensation Records
- Pay and bonus/incentive data by role, tied to individual performance metrics
- Documentation of how bonus or incentive structures are determined
- Compensation committee materials, if pay decisions are reviewed at that level
Training, Mentoring & Leadership Development Program Records
- Eligibility criteria for any formal or informal development, mentoring, or sponsorship program
- Enrollment and participation rosters for those programs
- Program charters or descriptions, “program participation” is defined broadly enough to capture informal programs, not just named initiatives
Internal Tracking, Dashboards & Reporting
- Any internal scorecards, dashboards, or reports that track workforce composition by business unit, manager, or team
- Diversity-related goals, targets, or metrics circulated internally, even informally
Governance, Policy & Subcontractor Records
- Written EEO and nondiscrimination policies, and DEI program documentation
- Board or leadership meeting minutes discussing workforce composition or diversity goals
- Documentation showing the clause was flowed down to subcontractors, and any known reports of subcontractor conduct that could implicate the clause
The request process itself is still being worked out, and these reviews will likely resemble targeted EEOC or DOJ-style document requests rather than a single standardized audit. Early guidance projects thousands of these compliance reviews per year across federal agencies — these are categories to have ready now, not to assemble after a request arrives.
That’s the series. For the full reference in one document, see the “How Federal Contractors Certify Nondiscrimination” guide.
This brief reflects publicly available regulatory information as of August 2026 and is provided for informational purposes only. Requirements may change; this does not constitute legal advice. Consult qualified consultants or a counsel regarding your specific obligations.
At HR Unlimited Inc., we help federal contractors and employers navigate complex compliance requirements while building stronger, more inclusive workplaces. 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.