What Federal Contractors Should Review Before October 26, 2026

Federal contractors and subcontractors have a regulatory change to prepare for this fall. The U.S. Department of Labor has published a final rule rescinding the regulations that implemented Executive Order 11246. The rule is scheduled to take effect on October 26, 2026.

This change is especially relevant for businesses that work on federal contracts, including some construction contractors and subcontractors. It does not mean that every part of your existing compliance process should be discarded immediately. It does mean that your business should review the documents, policies, and workflows connected to those regulations before the effective date.

The final rule published by the U.S. Department of Labor is the starting point for that review. Your company may also need advice based on its specific contracts and business structure.

Start With Your Federal Contract Documents

The first step is to identify which contracts and subcontracts may be affected. Do not rely only on a general assumption that the change applies to your company. Make a list of your current federal contracts, active subcontracts, renewals, and bids that may become contracts after the effective date.

For each agreement, look for the clauses and references connected to Executive Order 11246 and its implementing regulations. Review the main contract as well as any subcontractor agreements, amendments, purchase orders, and standard forms your team uses when work is passed to another business.

This is a good opportunity to improve document control. If your team has several versions of the same contract clause saved in different folders, create a single review list and record which version is being used for each project. A clear system can reduce the risk of sending an outdated form to a customer, subcontractor, or project manager.

If your business regularly works with subcontractors, your contract review should include the process used to communicate requirements to them. Our guide on Creating And Interpreting Subcontractor Agreements can help you organize that review, although the final rule itself should remain the authority for this specific change.

Review Equal Employment Policies Carefully

The rule affects regulations that implemented Executive Order 11246, so contractors should review the policies that were created or maintained because of those requirements. This may include equal employment opportunity statements, internal procedures, employee communications, onboarding materials, and policy language included in handbooks or contractor documents.

The practical question is not simply whether a policy mentions the executive order. Ask how the policy is used in daily operations:

• Is it included in offer letters, handbooks, or workplace notices?
• Does the hiring team use a standard process connected to the policy?
• Are managers trained to follow a particular procedure?
• Do subcontractor forms repeat the same language?
• Are there internal approvals or investigations that depend on the existing policy?

Keep a record of what you find. Separate policies that are required by a specific contract or regulation from broader company commitments that your business may choose to keep. A rescinded implementing regulation does not automatically answer whether a company should change every internal equal employment practice. Avoid removing a policy simply because one legal reference is changing.

Instead, mark each document for legal or compliance review and identify an owner for updating it. This can be an HR manager, operations leader, outside adviser, or another person with the authority to approve policy changes.

Check Recordkeeping And Reporting Workflows

Many businesses treat recordkeeping and reporting as administrative tasks, but those workflows are often built around specific regulatory requirements. A change to the regulations can affect what your team collects, where it stores information, and how it prepares reports or responses connected to federal contract work.

Review the records your company keeps for employees, applicants, job classifications, pay, hours, hiring decisions, and workplace actions. The goal is not to assume that every record can be deleted or that every reporting process should stop. The safer approach is to identify which records and reports are tied to the rescinded regulations, then confirm what should continue under the terms of your contracts and other applicable obligations.

Also review how information moves through your business. For example, determine:

• Who collects employee and applicant information?
• Who checks it for accuracy?
• Where are time, payroll, and personnel records stored?
• Who prepares reports for a federal customer or contracting team?
• How are corrections and approvals documented?
• Which reports are produced automatically from payroll or workforce software?

If your company uses a time tracking system, make sure its records can still be explained clearly. A reliable history of hours and job assignments can support payroll administration and project documentation, but it should not be treated as a substitute for understanding the specific requirements attached to a contract. For related payroll process improvements, see 5 Tips on How To Eliminate Payroll Mistakes.

Build A Review Plan Before The Effective Date

October 26, 2026 should be treated as a review deadline, not as the day your team begins looking for the relevant documents. Start by assigning one person to coordinate the project and create a short inventory of affected contracts, policies, forms, records, and reports.

Then use a simple status system: needs review, under review, approved, or replaced. Save the final versions in a location that managers and administrators can access, and remove outdated templates from the folders where staff normally look for forms. If an old document must be retained for historical reasons, label it clearly so it is not reused by mistake.

Document the decisions your company makes. If you keep a policy, record why. If you change a clause or reporting workflow, record when the change was approved and who approved it. This creates a useful internal trail and gives managers clear instructions when questions arise.

Finally, communicate the changes to the people who handle contracts, hiring, payroll, records, and subcontractor administration. The final rule creates a reason to review these processes together rather than treating each document as an isolated task. A focused review now can help your business avoid confusion when the rescission takes effect.