OFCCP announced it is reinstating a monthly reporting requirement (CC-257 Report) for federal construction contractors, nearly 30 years after discontinuing it.  Beginning April 15, 2025, covered construction contractors must submit a report to OFCCP by the 15th of each month, with detailed data on its number of employees and work hours by race/ethnicity and gender. 

In its announcement, the Agency explained it will use the monthly report to further its “mission of protecting workers in the construction trades, as employment discrimination continues to be a problem in the construction industry.”  OFCCP says the report will allow the Agency to strengthen both enforcement and compliance assistance. 

OFCCP proposed reinstating CC-257 in February 2024, and in its Supporting Statement, indicated that the report would allow the Agency to “better identify if there are potential hiring or job assignment issues that warrant further investigation during a compliance evaluation.”

The new reporting requirement will include data on number of employees and trade employees’ hours worked by race and gender within each Standard Metropolitan Statistical Area (SMSA) or Economic Area (EA) each month. For contractors with employees working on multiple projects, either within a SMSA/EA or across several areas, gathering and preparing the relevant data each month may prove challenging. Contractors must also include whether the work performed is designated by OFCCP as a Megaproject.  Other requirements include the contractor’s unique entity identifier (UEI) or Data Universal Numbering System (DUNS) number, both of which OFCCP uses to identify entities doing business with the federal government, and a list of the federal agencies funding their projects.

The Agency published Frequently Asked Questions on its CC-257 Report landing page and intends to provide additional compliance assistance, including a webinar, in early 2025. 

Please reach out to your Jackson Lewis attorney with any questions or for assistance in preparing for this new reporting requirement.

Tags: construction contractors, discrimination, OFCCP
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Photo of Laura A. Mitchell Laura A. Mitchell

Laura Mitchell is a principal in the Denver office of Jackson Lewis P.C. and leads the firm’s Workplace Analytics and Preventive Strategies Pay Equity subgroup. She partners with employers to evaluate, develop and implement policies and practices that ensure workplace fairness while mitigating…

Laura Mitchell is a principal in the Denver office of Jackson Lewis P.C. and leads the firm’s Workplace Analytics and Preventive Strategies Pay Equity subgroup. She partners with employers to evaluate, develop and implement policies and practices that ensure workplace fairness while mitigating legal risk. Laura is a guiding force in the firm’s most specialized and technical practice areas where she leverages an analytics-focused approach to partner with her clients in building legally compliant programs around which they can anchor their workplaces achieving productivity and stability.

Laura understands that creating a competitive advantage for employers in today’s workplace involves using a data-driven approach to counsel companies on the development of proactive and equitable non-discriminatory practices in hiring, promotions, separations and pay—and where advancements in technology can create both opportunities for efficiencies and risk that can be measured. Committed to putting her clients’ organizational goals first and foremost while balancing legal risk, Laura views herself as an extension of her clients’ team, responsible for providing proactive guidance and engaging in transparent, ongoing communication. Staying the course with employers across their organizational journey while balancing legal compliance obligations throughout their employees’ lifecycle ensures Laura’s position as a go-to resource.

Laura works with companies across all industries—both new and well-established multi-national organizations of all sizes—to realize the combined vision of legal compliance, increased productivity and economic growth enhanced by a focus on pay equity.  As part of the pay equity journey, she advises employers on the evolving pay transparency landscape, working to align compliant practices with the practical realities of the business world.

Laura partners closely with government contractors to understand, implement and demonstrate compliance with their EEO regulatory and compliance obligations. She also works closely with non-government contractor clients to conduct risk assessments of their programs, policies, and training to align with federal and state anti-discrimination requirements.

Laura is the editor and a principal contributor of the GovCon Employment Exchange blog and presents on pay equity and government contractor obligations. To round out her days, Laura enjoys spending time with her family and friends attending sports events, working out, riding her bike, playing pickleball and taking in Colorado’s incomparable sunsets.

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