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ARTICLE · 28 NOVEMBER 2025

Part II: Practical Compliance Roadmap And Strategic Outlook

To remain compliant and competitive under EO 14173, federal contractors should take immediate steps to realign their policies, data practices, and contracting procedures...

United StatesCompliance

To remain compliant and competitive under EO 14173, federal contractors should take immediate steps to realign their policies, data practices, and contracting procedures with the new merit-based framework.

The first step is to map your organization's federal exposure. Identify all contracts, subcontracts, and grants, both prime and sub, with federal agencies, including any flow-down obligations. This inventory clarifies where compliance responsibilities apply. Then determine whether your organization previously operated under EO 11246's affirmative-action structure and assess what has been done to wind down legacy programs such as Affirmative Action Plans or placement goals that may no longer be legally defensible.

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