Federal Construction Contractors and Subcontractors Face New Monthly Compliance Filing Requirements

The Office of Federal Contract Compliance Programs (OFCCP) has announced the reinstatement of a monthly compliance filing report for construction contractors and subcontractors. With an initial submission deadline set for April 15, 2025, these reports will be due every 15th of the month thereafter. Contractors and subcontractors subject to the new rules will need to submit their CC-257 reports to the OFCCP. Here are the answers to five of the most important questions surrounding this announcement from November 25.
Are We Affected?
Any business holding a federal construction contract or subcontract, or a federally assisted construction contract or subcontract, with a value exceeding $10,000 will be required to complete and submit this new monthly report.
What Needs to Be Reported?
The monthly report, which gathers employee demographic data (race and ethnicity, gender) across various construction trades, will include information on forepersons, journey workers, apprentices, trainees, and non-apprenticed laborers or helpers. Contractors may also add data for additional trades working in covered areas.
This report, which can be submitted in PDF or Excel formats, will use the EEOC’s current race and ethnicity categories: Hispanic or Latino, White, Black, Asian, Native Hawaiian or Other Pacific Islander, American Indian or Alaska Native, and Two or More Races. Contractors must also provide essential company details, including the Unique Entity ID (UEI), Employee Identification Number (EIN), and the awarding agency.
While contractors can choose to submit the report in either PDF or Excel, the OFCCP’s preferred submission method is through Excel, sent to the agency’s dedicated email address. The purpose of this reporting is to demonstrate the company’s workforce utilization, expressed in demographic terms.
Why Is the OFCCP Collecting This Information?
The OFCCP explains that the data collected will bolster its enforcement, outreach, and compliance support activities, helping the agency “better meet its mission of protecting workers in the construction trades.” This reporting initiative continues the ongoing compliance efforts following the landmark Infrastructure Investment and Jobs Act (IIJA). The OFCCP also anticipates that contractors can use the data to evaluate their equal employment opportunity efforts and take corrective actions throughout the life of a project, if needed.
What is the Deadline?
Construction contractors must submit their first monthly report by April 15, 2025, covering the previous month’s data. For example, the report due on April 15 will reflect the period from March 1 to March 31, 2025. Following that, the reports will be due on the 15th of each subsequent month. If the 15th falls on a weekend or federal holiday, the report will be due on the next business day.
How Should You Get Ready?
Given that this is the most frequent compliance reporting requirement from the OFCCP, contractors should take these five steps to prepare:
- Confirm if your company is required to comply. Only federal and federally assisted construction contractors are affected by this requirement.
- Revise your compliance reporting calendars to accommodate this monthly report.
- Ensure your HRIS or other tracking systems can capture, manage, and maintain the necessary demographic data.
- Review your utilization reports with legal counsel to evaluate trends.
- Evaluate your outreach and recruitment efforts based on the utilization data shown in the reports.
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