Federal contractors should prepare for a significant shift in compliance obligations following recent action by the Federal Acquisition Regulation (FAR) Council. In July 2026, the FAR Council indicated it will issue an interim final rule removing Executive Order 11246 requirements from the FAR, effectively dismantling the framework that has long required federal contractors to maintain affirmative action programs and related nondiscrimination measures. For contractors that have built their compliance infrastructure around these obligations over the past several decades, the pending change represents one of the most consequential regulatory developments in recent memory.
Executive Order 11246 has historically served as a cornerstone of federal contractor employment compliance, imposing affirmative action planning, recordkeeping, and reporting responsibilities on covered entities. The FAR Council's signaled rescission would unwind these long-standing obligations, altering how contractors approach workforce planning, applicant tracking, and internal audits. Companies with dedicated compliance functions, established written affirmative action programs, and periodic self-assessments will need to reevaluate whether existing policies and procedures remain necessary, appropriate, or advisable under the anticipated new framework.
The move reflects the Trump administration's broader deregulatory agenda and comes alongside signaled changes to other significant workplace rules. The administration has indicated potential revisions to independent contractor classification standards, joint employer analysis, and the H-1B program. Taken together, these developments suggest a wider realignment of federal workplace regulation with meaningful implications for hiring practices, workforce structure, and cross-border talent strategies. Contractors and employers should treat the anticipated FAR change not as an isolated adjustment but as one component of a broader regulatory shift.
In the interim, existing Executive Order 11246 obligations remain in effect until any final rule is issued and takes effect. Contractors should continue to comply with current requirements while monitoring developments, and should also consider how state and local nondiscrimination laws, other federal employment statutes, and internal corporate commitments may continue to inform their workforce practices regardless of the FAR change. Reviewing existing policies now will help position organizations to respond efficiently once the interim final rule is published.
This article is intended for general informational purposes only and does not constitute legal advice. Clients should consult qualified counsel for guidance tailored to their specific circumstances.