The proposed budgets are out for the fiscal year 2026 and it isn’t looking good for the Office of Federal Contract Compliance Programs (OFCCP). The budget plans of the U.S. Department of Labor’s (DOL) aim to fully eliminate the OFCCP beginning October 1, 2025.  

This article is part of an ongoing legal series designed to provide insight and practical guidance on current and emerging workplace compliance issues. These insights shared by lawyers are based on their interpretation of existing regulations and proposed changes, and intended for informational purposes, not to be regarded as legal advice.

Identifying and pursuing penalties against violators of immigration law is a top priority for the Trump administration. While most immigration enforcement changes impact non-citizens, businesses that employ noncitizens face increased risks, too. Generally, learning about how immigration status relates to the right to work, ensuring I-9 compliance, and keeping extensive and organized records are some of the most effective steps employers can proactively take to reduce those risks.

This article is the third in an OutSolve research series for HR professionals that provides an analysis of the Trump Administration’s proposed changes to I-9 employment eligibility verification and other issues related to having foreign nationals in your workforce. While recognizing that specific policy details are still emerging, this series draws on historical precedents, administration statements, and expert analysis to offer insights and provide practical guidance to HR leaders. 

In April 2025, a new Executive Order directed federal agencies to deprioritize enforcement actions based on disparate impact liability. This shift may reduce cases or pressure from the EEOC, but it doesn’t eliminate the legal or reputational risks your organization could face when policies result in unequal outcomes. 

OutSolve commissioned independent research on the state of immigration enforcement and the effect it may have on HR professionals. The information in these articles is provided for general education purposes.    

OutSolve commissioned independent research on the state of immigration enforcement and the effect it may have on HR professionals. The information in these articles is provided for general education purposes.   

Imagine an ICE agent walks into your workplace and hands you a Notice of Inspection (NOI) for a Form I-9 audit. What do you do? 

President Trump has nominated Brittany Panuccio to become a commissioner at the Equal Employment Opportunity Commission (EEOC). There are currently three empty seats on the five-member panel at the EEOC and this nomination, if approved, would fill one of them leaving two open.  

Before your company attests to no "illegal DEI," listen to our latest outRageous HR podcast: DEI or Discrimination? Navigating Policy Shifts While Staying Compliant. “When we certify with the government it comes with an extreme amount of penalties when you get it wrong,” says Kathlyn Perez. "You're telling the government...I don't believe there's discrimination in my programs or how my manager's are making decisions."

On April 15, 2025, ten former senior officials from the U.S. Department of Labor (DOL), including past leaders of the Office of Federal Contract Compliance Programs (OFCCP) and former Solicitors of Labor, released an open letter to federal contractors. This letter addresses the recent rescission of Executive Order (EO) 11246 by President Trump and the subsequent issuance of EO 14173, titled "Ending Illegal Discrimination and Restoring Merit-Based Opportunity."