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Affirmative action obligations and promoting diversity
  • Most employers no longer have affirmative action obligations.

In the past, certain federal contractors and subcontractors were obligated to have an affirmative action plan targeting their recruitment efforts at women or minorities. These obligations ended on January 21, 2025, when President Trump signed an executive order (EO) revoking EO 11246, which prohibited federal contractors and subcontractors from discriminating against employees and applicants based on their race, color, religion, sex, or national origin. However, certain requirements remain for:

  • Veterans under the Vietnam Era Veterans’ Readjustment Assistance Act (VEVRAA), and
  • Individuals with disabilities under the Rehabilitation Act of 1973.

These programs require federal contractors and subcontractors to ensure that individuals have an equal opportunity for employment, without regard to:

  • Disability
  • Protected veteran status

All employers should hire based on merit and qualifications. The Uniform Guidelines on Employee Selection Procedures offer guidance on avoiding adverse employment actions that may affect protected classes during the selection procedures.