Minnesota Workforce Certification Updates for 2025

Unlike previous years, 2025 brought more than just leadership change to federal contractors. Federal contractors have been busy bringing themselves into compliance with new obligations while balancing state laws, some of which contradict the changes imposed on contractors by the federal government. Usually, states are slow to change their processes to follow the lead of the federal government, but not in Minnesota.  

Shortly before March 2025, Minnesota’s Department of Human Rights (MDHR) began updating their reports to meet the needs of federal contractors who also contract with Minnesota. Just like most of our contractors, they quickly realized that changes needed to be made. 

What is the Minnesota Workforce Certificate? 

The Minnesota Workforce Certificates were created to ensure companies that do business with the state maintain a workplace free from discrimination under the Minnesota Human Rights Act. 

The Workforce Certificate is required to maintain or bid on a contract with the State of Minnesota or some of its municipalities where the award amount exceeds $100,000. This includes contracts with public institutions like universities. If the employer seeking to contract with Minnesota has more than 40 employees on a single day, then they must apply and maintain a Workforce Certificate.  

Part of the maintenance of the Workforce Certificate requires an annual review of the contractor’s demographics as it relates to race and gender as well as individuals with disabilities. The Certificate remains in place for four years, after which point, the contractor will be required to recertify to demonstrate that they are aware of and in compliance with Minnesota contractor workplace expectations.  

Construction contractors have a monthly obligation to report the demographics as they relate to the project for which they are contracted to perform, in addition to the annual review of the contractor’s overall workforce and recertification every four years.  

Key 2025 Updates to the Workforce Certificate 

There are several updates that Minnesota contractors must now follow. These changes took full effect on July 1, 2025.  

The first update is that the narrative Compliance Plan and EEO Policy Statement have been updated with any mention of affirmative action removed from both documents. Under these new updates, MDHR also removed the requirement to address underutilization goals and timetables. This means that Minnesota contractors can no longer opt to state they plan “to achieve the availability percentages for people of color or women in any and all job group(s) where [they] have identified underutilization.” Instead, they must now meet or exceed the availability percentage for women or people of color in all job groups. 

In addition, there are now two parts to the Annual Compliance Report.  

• Part One: Year in Review Narrative  
  • The Department of Human Rights will now require that Minnesota contractors verify their companies and contact information on a yearly basis through this document.  
  • They are now looking for contractors to demonstrate their good faith efforts to comply with obligations surrounding the Workforce Certificate.  
  • If a contractor, in evaluating its efforts, finds itself to be out of compliance, the state will be looking for a plan on how that contractor plans to address the issue and bring themselves into compliance with the expectations as part of the Workforce Certification. 
• Part Two: Annual Compliance Report Analysis 
  • This is similar to what has been requested in previous years, as far as data points are concerned. The state did, however, remove the affirmative action progress narrative tab seen in previous years. One might say that they took it out and created the Year in Review Narrative, which now holds contractors accountable for the efforts they make on a yearly basis.   

The timeframe for reporting data is expanding. For contractors who recertify or apply on or after July 1, 2025, you may now choose any date within a three-month period. 

Previously (and for the contractors who are not due to recertify their Workforce certification until after July 1, 2025), contractors had to use a one-year reporting period that ended on the same date of the month within a two-month period based on their certification end date.  

The state will now be checking to see that federal contractors are using the new reports for each submittal. MDHR will not be accepting the forms that have been traditionally part of the annual or recertification and application submittal process.  

Coming Soon: A Central Contractor Portal for Minnesota 

The Minnesota Department of Human Rights is working behind the scenes to create a portal for its contractors. This portal would act as Minnesota contractors’ main source for documents, communications, and even submittals. This will be a welcome change, given that the current process is to email the reports and all communications to a generic email address. 

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