On August 21, 2026, the Department of Labor’s (DOL) Office of Federal Contractor Compliance Programs (OFCCP) published three final rules addressing its regulatory framework following the revocation of EO 11246. One final rule rescinds the regulations that implemented EO 11246, while the other two modify the regulations implementing Section 503 of the Rehabilitation Act of 1973, as amended, and the Vietnam Era Veterans’ Readjustment Assistance Act (VEVRAA) of 1974, as amended. The Section 503 and VEVRAA changes are generally effective September 21, 2026, while the rescission of the EO 11246 implementing regulations is effective October 26, 2026.
Topics: Contracts & Subcontracts Administration, Human Resources, Government Regulations, Office of Federal Contract Compliance Programs, Organizational Change Management Consulting
The SBA’s final rule changes how individually owned firms establish social disadvantage for 8(a) eligibility by removing the rebuttable presumption and individual narrative test. Effective September 10, 2026, the new standard applies to pending and future applications and adds a requirement to show material harm resulting from discrimination or bias.
Topics: Litigation Consulting Support, Small Business Compliance, Contracts & Subcontracts Administration, Human Resources, Government Regulations
On April 20, 2026, the Defense Contract Audit Agency (DCAA) announced yet another reorganization: a transition to 23 “hub” organizations while maintaining office locations at key defense contractor sites. This reduction reduces the 180 office (branch and suboffices) locations to 23 hubs covering only 19 of the 50 states in the continental U.S.
Topics: Accounting System Compliance, Small Business Compliance, Contracts & Subcontracts Administration, DCAA Audit Support, Human Resources, Government Regulations, Organizational Change Management Consulting, Manufacturing Operations Consulting
On March 26, 2026, President Donald J. Trump signed an executive order (EO) titled, "Addressing DEI Discrimination by Federal Contractors." The order establishes new mandatory contract clause requirements for federal contractors and subcontractors at all tiers, creates reporting and monitoring obligations, and designates noncompliance as material under the False Claims Act (FCA). Federal agencies are required to incorporate the new clause into contracts and contract-like instruments by April 25, 2026. The EO applies to federal contracts, subcontracts, and contract-like instruments subject to the Federal Property and Administrative Services Act (40 U.S.C. § 101 et seq.).
Topics: Contracts & Subcontracts Administration, Human Resources, Government Regulations, Office of Federal Contract Compliance Programs, Organizational Change Management Consulting
Employers responding to ADA accommodation requests face growing compliance risks when requests are handled inconsistently, delayed, or insufficiently documented. Recent enforcement activity highlights the importance of a timely, individualized process that aligns with legal requirements, protects employee rights, and reduces exposure to claims and litigation.
Topics: Litigation Consulting Support, Contracts & Subcontracts Administration, Human Resources, Government Regulations, Office of Federal Contract Compliance Programs, Organizational Change Management Consulting, Manufacturing Operations Consulting, Employers & Unions
For the last few years, our friends at the Defense Contract Audit Agency (DCAA) have been very helpful by publishing the Contractor Compensation Cap in the December timeframe. This year, I am guessing that the Government shutdown has diverted their attention. To help our clients, we have calculated the 2026 amount of the cap.
Topics: Accounting System Compliance, Proposal Cost Volume Development & Pricing, Employee & Contractor Compensation, Incurred Cost Proposal Submission (ICP/ICE), DCAA Audit Support, Human Resources, Government Regulations, Federal Acquisition Regulation (FAR)
EO 14173 revoked EO 11246 Equal Employment Opportunity, which required covered federal contractors to practice affirmative action, develop written Affirmative Action Plans (AAPs) and implement compliant programs directed towards equal opportunities for women and minorities. This major change left contractors with a choice: set aside all efforts previously made toward compliance with EO 11246, or continue with employment analytics under a framework acceptable under EO 14173. In this article, we explain why we encourage you to consider the continuation of these efforts.
Topics: Contracts & Subcontracts Administration, Human Resources, Government Regulations, Office of Federal Contract Compliance Programs, Service Contract Act
September 2026 Update
Since this article was published, OFCCP has finalized additional regulatory changes affecting government contractors. On August 21, 2026, DOL published final rules revising the regulations implementing Section 503 and VEVRAA and rescinding the regulations that implemented EO 11246. Most Section 503 and VEVRAA changes take effect September 21, 2026. Read our latest Client Alert for a breakdown of the updated requirements and key compliance dates.
Topics: Small Business Compliance, Contracts & Subcontracts Administration, Human Resources, Government Regulations, Office of Federal Contract Compliance Programs, Service Contract Act
As employers, balancing the needs of the business while also addressing workers’ legitimate requests can be challenging during a union strike or work stoppage. However, having the best knowledge and engaging in a proactive approach can be an opportunity to build stronger and more resilient labor relations. Strikes do not have to equate to a crisis. Understanding why they happen and knowing how to prevent or manage them effectively can make all the difference.
Topics: Human Resources, Organizational Change Management Consulting, Manufacturing Operations Consulting, Employers & Unions
A well-configured HR system can feel like the backbone of a thriving organization by streamlining processes, enhancing employee experience, and offering powerful data insights. However, even the most advanced HR technology can quickly become a liability if one critical element is overlooked - compliance. Government contractors risk turning their greatest HR asset into a hidden source of vulnerability if they fail to consider compliance in their implementation strategy.
Topics: Small Business Compliance, Contracts & Subcontracts Administration, DCAA Audit Support, Human Resources, Government Regulations, Office of Federal Contract Compliance Programs, Service Contract Act, Organizational Change Management Consulting, UKG Ready HR Software Consulting
