Federal Contractor Poster Updates

Federal Contractor Labor Law Changes: EEO, Minimum Wage and Pay Transparency

Federal contractors and subcontractors have historically faced additional employment law requirements involving equal employment opportunity, minimum wages, pay transparency, and workplace notices.

Several important changes occurred during 2015 and 2016, when federal agencies implemented new contractor-related rules and posting requirements. Since then, additional executive orders, court decisions, and agency actions have significantly changed the federal contractor compliance landscape.

This article reviews those historical developments and explains why employers should verify current requirements before relying on older federal contractor workplace notices.

Federal Contractor Requirements Under Executive Order 11246

Executive Order 11246 historically established equal employment opportunity and affirmative action requirements for certain federal contractors and subcontractors.

Contractors covered by the order were subject to additional obligations administered by the U.S. Department of Labor's Office of Federal Contract Compliance Programs (OFCCP).

In January 2025, Executive Order 14173 revoked Executive Order 11246. The Department of Labor subsequently took steps to rescind regulations implementing the revoked order.

Federal contractors should not assume that historical Executive Order 11246 requirements remain applicable. Other federal contractor obligations may continue under separate statutes, regulations, and contract provisions.

1. Federal Contractor Minimum Wage Changes

In February 2014, President Barack Obama signed Executive Order 13658, establishing a minimum wage for workers performing on or in connection with certain covered federal contracts.

The initial contractor minimum wage was $10.10 per hour beginning January 1, 2015. For 2016, the rate increased to $10.15 per hour, with a separate cash wage requirement for covered tipped employees.

These requirements were subject to subsequent annual adjustments.

In 2021, Executive Order 14026 introduced a separate federal contractor minimum wage framework. However, Executive Order 14026 was revoked in March 2025, and the Department of Labor announced that it would no longer enforce that order or its implementing regulations.

Executive Order 13658 has a separate legal framework that may continue to apply to qualifying contracts.

Employers should review the applicable contract dates, contract provisions, and current Department of Labor guidance before determining federal contractor wage obligations.

2. Historical EEO Is the Law Supplement

During 2015, federal contractors were required to address revisions involving equal employment opportunity protections and related workplace notices.

The historical EEO Is the Law Supplement included information concerning discrimination protections, pay secrecy, individuals with disabilities, and protected veterans.

At the time, covered federal contractors displayed the supplement together with the existing EEO Is the Law poster.

These historical materials should not be treated as the current EEOC workplace discrimination poster.

3. EEOC Know Your Rights Poster Replaced the Previous EEO Notice

In October 2022, the U.S. Equal Employment Opportunity Commission released the Know Your Rights: Workplace Discrimination Is Illegal poster.

The updated notice replaced the previous EEO Is the Law poster and its supplement.

The EEOC subsequently revised the Know Your Rights notice to address additional protections, including the Pregnant Workers Fairness Act.

Covered employers should review the current official EEOC poster and applicable posting requirements rather than continuing to display obsolete versions.

For official information, visit the EEOC Know Your Rights Poster page.

4. Pay Transparency and Executive Order 13665

Executive Order 13665, signed in 2014, amended the federal contractor nondiscrimination framework under Executive Order 11246.

The related regulations addressed discrimination against applicants and employees for inquiring about, disclosing, or discussing compensation, subject to specified limitations.

Historically, covered federal contractors were required to communicate the Pay Transparency Nondiscrimination Provision to applicants and employees.

However, the 2025 revocation of Executive Order 11246 and subsequent regulatory changes affected the legal framework supporting these federal contractor requirements.

In August 2026, the Department of Labor published a final rule rescinding regulations implementing Executive Order 11246, including associated pay transparency provisions.

Employers should therefore avoid relying on outdated statements that the former Executive Order 11246 pay transparency notice remains universally mandatory for federal contractors.

Separate federal, state, and local laws may continue to protect employees' rights concerning compensation discussions.

5. Protections for Veterans and Individuals With Disabilities

Federal contractor requirements involving protected veterans and individuals with disabilities have also evolved over time.

The Vietnam Era Veterans' Readjustment Assistance Act (VEVRAA) and Section 503 of the Rehabilitation Act establish separate statutory frameworks for covered federal contractors.

These requirements are distinct from the historical Executive Order 11246 framework.

Depending on applicable coverage rules, contractors may have obligations involving nondiscrimination, affirmative action, recruitment, recordkeeping, and employee notices.

Employers should review current OFCCP guidance to determine which requirements apply to their contracts and workforce.

Which Federal Contractor Labor Law Posters May Be Required?

Federal contractors may be subject to workplace posting requirements under several different laws and contract-related provisions.

Depending on the employer's activities and contract coverage, relevant notices may involve:

• Equal employment opportunity protections.
• Federal minimum wage and overtime requirements.
• Occupational safety and health protections.
• Employee polygraph protection requirements.
• Family and medical leave rights.
• Protected veterans' employment rights.
• Rights of individuals with disabilities.
• Applicable federal contractor wage and labor standards.
• Other contract-specific workplace notice requirements.

Not every notice applies to every federal contractor. Employers should review the governing statute, regulation, and contract provisions before determining which postings are required.

Why Federal Contractors Should Review Older Workplace Posters

Federal contractor employment requirements may change through executive orders, legislation, agency rulemaking, and court decisions.

A poster that accurately described requirements in 2015 or 2016 may no longer reflect the applicable law.

Employers should periodically review official agency notices and replace outdated materials when required.

Federal Contractor Workplace Posting Resources

Labor Law Compliance Center provides federal workplace notices and additional labor law posting products for employers throughout the United States.

Browse our Federal Labor Law Posters category for available federal workplace notices.

Employers can also explore our State and Federal Combination Labor Law Posters or learn more about our Poster Replacement Plan.

Frequently Asked Questions About Federal Contractor Labor Laws

Is Executive Order 11246 still in effect?

No. Executive Order 11246 was revoked in January 2025. Employers should review current federal contractor requirements under other applicable authorities.

Is the old EEO Is the Law Supplement still the required EEOC poster?

No. The EEOC's Know Your Rights poster replaced the former EEO Is the Law poster and supplement in 2022. Covered employers should use the applicable current notice.

Do federal contractors have additional workplace posting requirements?

Some do. Requirements depend on the employer's contract coverage, workforce, and applicable laws. Federal contractor status alone does not establish that every contractor-specific notice is required.

Do federal contractor minimum wage requirements still exist?

Some requirements may continue to apply under Executive Order 13658 and other applicable laws or contract provisions. Executive Order 14026 was revoked in 2025. Employers should verify current rules for their particular contracts.

How can employers keep federal contractor posters current?

Employers should monitor official agency guidance, review applicable contract provisions, and replace required notices when the governing requirements change.

Official Federal Contractor Compliance Resources

For current federal contractor guidance, employers may consult:

• U.S. Department of Labor - OFCCP
• EEOC - Know Your Rights Poster
• Department of Labor - Federal Contractor Minimum Wage

Compliance note: This article discusses historical federal contractor employment law developments and subsequent regulatory changes. It is not a determination of current obligations for any particular contract. Employers should consult current official agency guidance and applicable contract provisions.