Part I: The New Compliance Landscape Under EO 14173

In her recent remarks, former OFCCP Director Catherine Eschbach emphasized that the compliance environment for federal contractors is undergoing a profound transformation under Executive Order 14173, "Ending Illegal Discrimination and Restoring Merit-Based Opportunity." She explained that this order establishes a "whole-of-government approach" to identifying and eliminating unlawful DEI practices, meaning that oversight will no longer rest solely with the OFCCP. Instead, agencies that award grants, approve mergers and licenses, or enforce the False Claims Act will also scrutinize employers' inclusion and diversity programs to ensure they do not cross into impermissible territory.