Starting April 15, 2025, federal construction contractors will be required to submit monthly employment data through the reinstated CC-257 Report. This report will track employee numbers and work hours, broken down by race/ethnicity and gender.

Key Points

‍Federal contractors will need to compile detailed monthly data for employees on federal contracts, which could be particularly challenging for those working across multiple projects. Contractors should begin assessing their compliance programs and data reporting capabilities in preparation for the change.

OFCCP’s Decision

The Office of Federal Contract Compliance Programs (OFCCP) announced on November 25, 2024, that starting on April 15, 2025, construction contractors will be required to submit monthly employment data for the first time in almost 30 years. The reinstated CC-257 Report will collect data about the number of employees and work hours by race/ethnicity and gender. This report will be submitted by the 15th of each month for all businesses with federal or federally assisted contracts or subcontracts.

In its Frequently Asked Questions section, OFCCP highlighted its goal to use the monthly data report to advance its mission “of protecting workers in the construction trades, as employment discrimination continues to be a problem in the construction industry.” The report will also enhance enforcement and compliance assistance.

The Supporting Statement released by the agency in February 2024 explained that the reinstated report would help OFCCP “better identify if there are potential hiring or job assignment issues that warrant further investigation during a compliance evaluation.” Contractors who fail to submit the required reports on time may face sanctions and could be subject to compliance reviews.

New Reporting Requirements

The new reporting mandate will include data on:

• Employee count and trade workers’ hours worked by race/ethnicity and gender for each Standard Metropolitan Statistical Area (SMSA) or Economic Area (EA).

Mega Projects

Contractors must specify whether the work is classified as a Megaproject, a designation for projects with a value of at least $35 million. OFCCP will engage directly with contractors and subcontractors on these large-scale projects, including regular meetings with stakeholders.

Other requirements include a unique entity identifier (UEI) or DUNS number, and a list of federal agencies funding the projects.

Submission

Contractors will email an Excel version of the report to the OFCCP. For technical inquiries, contractors can contact OFCCP’s Help Desk.

Looking Ahead

While the reinstatement of the reporting requirement is a significant change, it may be subject to modification by the new administration under President Trump. As the future of this rule remains uncertain, construction contractors are encouraged to assess their current compliance programs and update their data reporting capabilities. Starting now can ensure a smoother transition to the new reporting obligations.

The OFCCP also plans to provide compliance assistance, including outreach and webinars for contractors in early 2025.