On April 15, 2025, ten former senior officials from the U.S. Department of Labor (DOL), including past leaders of the Office of Federal Contract Compliance Programs (OFCCP) and former Solicitors of Labor, released an open letter to federal contractors. This letter addresses the recent rescission of Executive Order (EO) 11246 by President Trump and the subsequent issuance of EO 14173, titled "Ending Illegal Discrimination and Restoring Merit-Based Opportunity." 

Human Resources professionals understand how important and challenging it can be to remain updated and compliant with labor laws. This is especially true when managing multiple locations or remote employees across different states. One component of multi-state HR compliance includes ensuring you meet all state and federal labor law poster requirements.  

April is here and with that comes the end of the 90-day safe harbor period for federal contractors complying with EO 11246. As April 21, 2025, approaches, federal contractors are obligated to transition away from EO 11246 requirements, or affirmative action plans (AAP) for women and minorities to EO 14173. 

Ever wondered what would happen if everyone at your office suddenly knew each other’s salaries? Would your team leave feeling angry and defeated or would they be satisfied knowing they are paid their worth and in-line with other folks in the same role make?  

The U.S. Department of Labor (DOL) announced their new Director of the Office of Federal Contract Compliance Programs (OFCCP) on March 24, 2025. Catherine Eschbach will now lead the department in its transition from EO 11246 to EO 14173, Ending Illegal Discrimination and Restoring Merit-Based Opportunity. Eschbach is quoted as saying she will work to “restore a merit-based system to provide all workers with equal opportunity.” 

The U.S. Equal Employment Opportunity Commission (EEOC) and the Department of Justice (DOJ) jointly issued a press release on Wednesday, March 19, 2025, that gave some further clarification on unlawful discrimination related to Diversity, Equity, and Inclusion (DEI). 

There have been a flurry of changes to federal contractor obligations this year with a lot still unknown. Many Executive Orders issued by President Trump have directly impacted labor laws and reporting requirements. Labor law posters are no exception to these changes.  

“The only certainty right now in the federal government is uncertainty." –Jeremy Mancheski

The information provided herein is for general informational purposes only and does not constitute legal advice. This content reflects analysis of publicly available court filings and executive orders. 

Key implications of the February 21, 2025 injunction and what’s next for federal contractors, universities, and corporations