EO 11246 Is Ending. EEO-1 May Change. What Should Federal Contractors Do Now?
Federal contractors should not treat the EO 11246 rescission and the EEO-1 proposal as one “stop collecting data” event. One is a final regulatory change with an October effective date. The other is a proposal that has not changed current employer obligations.
The practical challenge is deciding what to change and what to preserve without disrupting systems that still support compliance, contracts, or workforce decisions.
1. Separate the two developments
EO 11246: OFCCP finalized the rescission of regulations implementing EO 11246. The formal rescission takes effect October 26, 2026. This affects historical race- and sex-based affirmative-action requirements associated with that executive order.
EEO-1: The EEOC has proposed rescinding annual race- and sex-data reporting requirements, including EEO-1 reporting. The proposal is not a current exemption. Employers should continue current EEO-1 preparation, reporting, and data-quality practices unless a final rule takes effect.
2. Create a workforce-data inventory
You cannot make a controlled decision about data you cannot see. Start with the systems that collect, store, or report workforce information:
Applicant tracking systems
HRIS and onboarding platforms
Payroll and timekeeping systems
Benefits and leave platforms
Workforce analytics dashboards
Spreadsheets, shared drives, and internal reports
Recruiting, onboarding, background-check, and HR technology vendors
For each data point or report, document four essentials:
3. Protect data that still serves a purpose
The EO 11246 rescission does not automatically end all uses for demographic and workforce data. The same information may still support Title VII compliance, state or local obligations, customer requirements, investigations, litigation holds, internal pay analysis, or workforce planning. Do not delete records merely because one federal requirement changes.
4. Limit access to sensitive information
Good governance is as much about preventing unnecessary access as it is preserving data. Review who can view, export, edit, or distribute sensitive workforce information. Pay close attention to reporting dashboards, downloaded spreadsheets, recurring email reports, vendor permissions, and shared folders.
5. Make changes in a controlled sequence
Do not ask one HRIS administrator to interpret a regulatory development and make a systemwide change alone.
Use a simple sequence:
Identify the proposed change.
Confirm the requirement and effective date.
Map affected systems, reports, vendors, and records.
Obtain cross-functional approval.
Test the change before release.
Retain an approval record and implementation evidence.
Confirm that Section 503 and VEVRAA workflows still function as intended.
This sequence reduces both types of risk: acting too early and preserving sensitive data without a clear purpose.