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ARTICLE · 01 SEPTEMBER 2016

Final Fair Pay Rules Are Here: Contractors Face Complex Requirements And Challenges With New Reporting Obligations

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The federal government released the final regulations implementing the Fair Pay and Safe Workplaces Executive Order this week.

United StatesEmployment and HR
Christopher Wilkinson
Christopher Wilkinson
Jill Rosenberg
Jill Rosenberg
Gary Siniscalco
Gary Siniscalco
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The federal government released the final regulations implementing the Fair Pay and Safe Workplaces Executive Order ("EO" hereafter) this week. The regulatory package contains two parts: amendments to the Federal Acquisition Regulations and guidance from the Department of Labor for implementing the regulations. The regulatory package is a central part of the Administration's aggressive regulatory agenda we have previously discussed and reflects continuing burdens on federal contractors.

How We Got Here

The rule-making began with Executive Order 13673. Features of the EO include:

  • Requiring that contractors and subcontractors with over $500,000 in federal contracts report any "administrative merits determination, arbitral award or decision or civil judgment" arising out of 14 enumerated federal labor laws and the state equivalents in the preceding 3-year period;1

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