Hunton Employment & Labor Perspectives

The Office of Federal Contract Compliance Programs (OFCCP) is reinstating the Monthly Employment Utilization Report (CC-257), which will require businesses with federal construction contracts to report employee work hours and headcounts by race/ethnicity, gender, and trade. Specifically, this report applies to companies with contracts or subcontracts exceeding $10,000 in federal construction or federally assisted construction work.

The CC-257 report is due by the 15th of each month, covering the previous calendar month. If the 15th falls on a weekend or holiday, the report is due on the next business day. The first report will cover March 2025 and is due by April 15, 2025.

This reinstatement seeks to strengthen OFCCP’s enforcement and compliance efforts, focusing on protecting workers from employment discrimination. The report will also help contractors monitor their equal employment opportunity practices, allowing them to take corrective action if needed.

OFCCP will provide ample outreach to support contractors in meeting the reporting requirements, including a webinar in early 2025. More details about the reporting requirements, due dates, and compliance support resources can be found at OFCCP's official page on the CC-257 report.

While the first report is not required until Spring 2025, federal contractors should anticipate additional changes. All employers, including federal contractors, should anticipate several changes within the incoming administration. Federal contractors should work closely with counsel to monitor the legal landscape and expect many changes in the coming years (resulting from both the change in administration and legal developments from recent Supreme Court cases).