Quick Hits
- OFCCP announced that its new Form CC-257 required monthly employment data reporting for covered federal contractors and subcontractors will launch in March 2025 and be due by April 15, 2025.
- Reports will cover a calendar month and be due the fifteenth of the following month unless the fifteenth falls on a weekend or holiday, on which the report will be due the next business day.
- The new reports are the latest of several changes in 2024 by OFCCP to contractor and subcontractor reporting obligations.
OFCCP stated that it is moving forward with the reinstatement of the Monthly Employment Utilization Report (CC-257), which will require federal contractors, subcontractors, and/or federally assisted construction contracts of $10,000 to report employee work and race/ethnicity, gender, and trade data.
OFCCP said the first report, covering March 2025, will be due on April 15, 2025. Reports will be required to cover a full calendar month and will be due by the fifteenth of the following month unless the fifteenth falls on a weekend or holiday, on which the report will be due the next business day.
The form requires construction contractors to report certain information for each standard metropolitan statistical area (SMSA) or economic area (EA).
According to OFCCP, “[t]he CC-257 report will strengthen OFCCP’s enforcement, outreach and compliance assistance activities” as the agency seeks to address employment discrimination, which “continues to be a problem in the construction industry.” OFCCP further stated that contractors can use the monthly reports to “proactively monitor their equal employment opportunity efforts and take corrective measures.”
The announcement comes after the federal Office of Management and Budget (OMB) gave final approval to the new Form CC-257 in September 2024. The new reporting further comes after OFCCP, earlier in 2024, issued a new construction scheduling letter and renewed and revised Form CC-314, which is used by covered construction contracts to report new federal or federally assisted contracts or subcontracts exceeding $10,000.
Next Steps
OFCCP said versions of the report will be available on the agency’s CC-257 Report website. More information on Form CC-257 and the new reporting requirements is available here.
However, employers may want to note the possibility that the reporting requirements could change with the new presidential administration. At this time, it is unclear whether the incoming Trump Administration will keep this new reporting requirement in place or nix it after taking office before the first reporting deadline.
Ogletree Deakins’ OFCCP Compliance, Government Contracting, and Reporting Practice Group will continue to monitor developments and will provide updates on the Construction, Government Contractors, and OFCCP Compliance, Government Contracting, and Reporting blogs as additional information becomes available.
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