Required Federal & State Reporting – 2025

Following the recent changes introduced by the administration, here is a summary of what’s changed and what stays the same regarding OFCCP, VETS, and EEOC, and how Kairos will continue to meet your compliance needs.

Federal and State Reporting Requirements

The following are required reports and AAPs (if applicable):

1. Section 503 of the Rehabilitation Act of 1973 (AAP for Individuals with Disabilities)
2. Vietnam Era Veterans’ Readjustment and Assistance Act (AAP for Veterans)
3. EEO-1 Reports
4. VETS-4212 Reports
5. AAPs for state-level reporting, as required
6. Equal pay reporting and analyses for state-level compliance, as required¹

In the coming months, AAPs and analyses pursuant to Executive Order 11246 are optional unless your state, county, or municipal regulations require a similar type of compliance reporting.²

Upcoming Certification Requirements

The new Executive Order (EO), “Ending Illegal Discrimination and Restoring Merit-Based Opportunity,” includes a provision requiring federal contractors to:

• Agree that their operations comply with all applicable federal anti-discrimination laws (Sec. 3.(b)(iv)(A)).
• Certify that they do not operate any programs promoting DEI (diversity, equity, and inclusion) that violate federal anti-discrimination laws (Sec. 3.(b)(iv)(B)).

The mechanism for this certification is still unclear. It may be implemented as:

• A checkmark during the procurement process.
• An attestation submitted via OFCCP’s Contractor Portal.

We will monitor developments closely and provide updates to keep you informed.

Kairos Support and Proactive Analyses

Kairos is committed to supporting your compliance efforts through comprehensive analyses and technical consultation. We will continue to prepare all our current anti-discrimination and bias analyses to bolster your nondiscrimination practices pursuant to Title VII, Equal Pay Act, ADA, etc. Additionally, Kairos will continue to provide technical support, consultations, and access to our continually expanding Client Portal, at no additional charge.

Navigating Compliance Amid Evolving Expectations

As you evaluate your compliance strategy, it is important to consider that reducing or eliminating DEI programs and employee resource groups (ERGs) could present risks. While current executive orders aim to discourage illegal DEI programs (ones encouraging decisions based on race or gender) scaling back your equal opportunity compliance efforts without proper communication and ongoing assessment could lead to increased discrimination complaints.³ Kairos is committed to supporting you through these challenging times by providing comprehensive training and ensuring compliance with both federal and state regulations. Our goal is to help you maintain a fair and equitable workplace. If you have any questions or need additional guidance, please don’t hesitate to reach out.

¹  The following states may require state equal pay reporting based on business in or with state or municipalities within the state: CA, IL, MA, MN, and NJ.

²  The following states may require affirmative action programs based on business in or with state or municipalities within the state: CA, CT, DC, HI, IL, KY, MN, OH, PA, WA, and WI.

³  Wiessner, D. (2025, January 24). Despite Trump order, abandoning DEI could land companies in legal trouble. Reuters. https://www.reuters.com/business/despite-trump-order-abandoning-dei-could-land-companies-legal-trouble-2025-01-24/