DCI Consulting Blog

By David Cohen, Joanna Colosimo & Amanda Bowman

BLOG OVERVIEW: The FAR Council has released FAR 52.222-90, a new contract clause implementing Executive Order 14398 that prohibits federal contractors and subcontractors from engaging in race- or...

By Tyler Wurtz

BLOG OVERVIEW: Czechia has released a draft proposal to implement the European Union (EU) Pay Transparency Directive, taking a self-described "minimalist" approach to transposition. The proposal introduces requirements for recruitment...

By Joanna Colosimo

BLOG OVERVIEW: On April 10, 2026, DOJ announced a $17 million False Claims Act settlement with IBM—the first resolution under the Civil Rights Fraud Initiative—over allegations that IBM's DEI-related employment practices violated...

By Grace Boudjalis

BLOG OVERVIEW: Colorado's landmark AI Act (SB 24-205) faces a potential overhaul as Governor Polis' AI Policy Working Group has developed the KILO draft, a proposed replacement framework that shifts from prescriptive governance...

By Joanna Colosimo

BLOG OVERVIEW: The proposed FY 2027 White House budget includes the elimination of OFCCP—transferring Section 503 and VEVRAA enforcement to a new Office of Civil Rights within the Department of Labor—and increased EEOC funding,...

 By Amanda D. Allen and Bre Timko

BLOG OVERVIEW: Despite the Trump Administration’s Executive Order 14281 directing federal agencies to deprioritize disparate impact enforcement and the EEOC’s decision to close disparate-impact-only investigations,...

By Victoria Ungvary and Kate Hayek

BLOG OVERVIEW: The 2025 California Pay Data Report introduces new optional data fields, causing confusion among employers about filing requirements. Despite initial impressions from CRD's FAQ that exemption status,...

By David Cohen

BLOG OVERVIEW: On March 26, 2026, President Trump signed an executive order targeting racially discriminatory DEI activities by federal contractors, with enforcement mechanisms including contract termination, debarment, and False...

Disability Self-ID Form Expiration Date Approaching: What Federal Contractors Need to Know

By Macy Cheeks and Victoria Ungvary

BLOG OVERVIEW: OFCCP's Voluntary Self-Identification of Disability Form (CC-305) is set to expire on April 30, 2026. Under...

By Fred Satterwhite

BLOG OVERVIEW: Executive Order 14173’s revocation of EO 11246 continues to reshape the federal contracting landscape, with GSA removing three FAR provisions related to affirmative action representations and certifications from...

By Benjamin Kerner

BLOG OVERVIEW: In January 2026, the Netherlands published draft legislation to transpose the EU Pay Transparency Directive by amending its Equal Treatment of Men and Women Act of 1980. The proposed changes emphasize job evaluation...

By Zhuang Liu

BLOG OVERVIEW: On February 5, 2026, Italy's Council of Ministers gave preliminary approval of a draft legislative decree implementing the EU Pay Transparency Directive (2023/970/EU), marking a significant step toward the June 7, 2026,...

By Loi Tan

BLOG OVERVIEW: On February 26, 2026, Denmark's Ministry of Employment published a draft bill to transpose the EU Pay Transparency Directive (2023/970) into Danish law through amendments to the Equal Pay Act, with the law expected to take...

By Murray Simpson, Ph.D.

BLOG OVERVIEW: The EU Pay Transparency Directive (Directive (EU) 2023/970) requires all EU member states to transpose binding pay transparency and pay equity obligations into national law by June 7, 2026, with gender pay gap...

By Fred Satterwhite

BLOG OVERVIEW: OFCCP Director Ashley Romanias has announced a major reorganization of the Office of Federal Contract Compliance Programs (OFCCP), consolidating field operations and policy functions into two streamlined divisions....

By Stephanie Horn

BLOG OVERVIEW: New pay transparency laws are reshaping hiring practices across the U.S., with California, Massachusetts, Columbus (Ohio), and Delaware each enacting requirements that mandate employers disclose salary ranges in job...

By Bre Timko & Dave Schmidt

BLOG OVERVIEW: A recent audit by the New York State Comptroller's Office revealed significant shortcomings in New York City's enforcement of Local Law 144 (LL144), the landmark legislation requiring bias audits of...

By Cassie Alfheim and Amanda Bowman

BLOG OVERVIEW: On January 28, 2026, the General Services Administration (GSA) proposed changes to SAM registration requirements that would add a DEI certification for federal financial assistance recipients,...

By Don Lustenberger

BLOG OVERVIEW: The European Union Pay Transparency Directive requires employers to report gender pay gaps for categories of workers performing "the same work or work of equal value"—two complementary but distinct legal concepts....

By Joanna Colosimo

On February 11, 2026, OFCCP notified contractors that the Ninth Circuit district court lifted a temporary stay on the release of EEO-1 records from 2016-2020 as a part of an ongoing suit (Center for Investigative Reporting v....

By Brittany Dian-Hansell

Blog Overview: Finland has released a draft proposal to implement the European Union (EU) Pay Transparency Directive. Employers with employees in Finland should be prepared for the legislation to take effect in May of 2026...

By Fred Satterwhite

On January 30, 2026, the U.S. Federal Trade Commission (FTC) sent letters to 42 law firms warning that their participation in a diversity certification program could potentially create liability under federal antitrust laws that...

By Joanna Colosimo

On February 3, 2026, President Trump signed a spending bill that includes funding for the Department of Labor. The bill allocates just under $101 million for the Office of Federal Contract Compliance Programs (OFCCP) for fiscal...

By Benjamin Kerner

Federal contractors and subcontractors that meet jurisdictional thresholds may be due to re-survey their active workforces for disability status to remain compliant with Section 503 of the Rehabilitation Act of 1973 (Section...

By Brittany Dian-Hansell

Following a temporary period of administrative abeyance in 2025 after the revocation of Executive Order 11246, DCI can confirm that the Office of Federal Contract Compliance Programs (OFCCP) has resumed processing and...

By Victoria Ungvary and Emily Kimble

Update: The California Civil Rights Department has re-uploaded the Excel templates it previously removed from its site with no substantive changes.

BLOG OVERVIEW: The California Civil Rights Department has...

By Keli Wilson

BLOG OVERVIEW: Following President Trump's Executive Order 14173, federal contractors face significant changes to equal employment opportunity compliance requirements. While federal agencies continue submitting annual MD-715 reports...

By Joanna Colosimo

In the year following the revocation of Executive Order 11246, the federal contractor community has been closely watching the Office of Federal Contract Compliance Programs (OFCCP) for signs of what might come next. In the last...

By Emily Kimble

Blog Overview: The California Civil Rights Department (CRD) has published updated templates for the 2026 California Pay Data Reports. These templates include multiple new requirements for the 2025 reporting year. Employers should...

By Fred Satterwhite

BLOG OVERVIEW: The Department of Education's new Admissions and Consumer Transparency Supplement (ACTS) requires four-year colleges and universities to report seven years of detailed student-level admissions data through the...

By Mitchell Chamberlin

New Pay Transparency Requirements

Amendments to Poland’s Labor Code went into effect on December 23, 2025 as part of the nation’s efforts to implement European Union Directive 2023/970, otherwise known as the European Union...

By Lily Kerr

Blog Overview: The Office of Federal Contract Compliance Programs (OFCCP) published an Information Collection Request on January 7, 2025, seeking reauthorization to enforce Vietnam Era Veterans' Readjustment Assistance Act (VEVRAA)...