We’ve learned the Office of Management and Budget has received for consideration the proposed regulations and guidance implementing the Fair Pay & Safe Workplaces Executive Order.  This is the next step in the regulatory review process and indicates the regulations and guidance are one step closer to finalization.  To be clear, the documents need OMB approval before being final.

And given the controversy surrounding the order and the implementing documents, its anticipated there will be legal challenges initiated soon after the regulations and guidance are finalized.

Whether changes have been made to the proposed regulations and/or guidance is unknown at this point as the version of the documents sent to OMB are not public at this time.

It remains to be seen how long OMB will take to review the proposals but we will update as soon as we have additional information.