OFCCP announced it is reinstating a monthly reporting requirement (CC-257 Report) for federal construction contractors, nearly 30 years after discontinuing it.  Beginning April 15, 2025, covered construction contractors must submit a report to OFCCP by the 15th of each month, with detailed data on its number of employees and work hours by race/ethnicity and gender. 

In its announcement, the Agency explained it will use the monthly report to further its “mission of protecting workers in the construction trades, as employment discrimination continues to be a problem in the construction industry.”  OFCCP says the report will allow the Agency to strengthen both enforcement and compliance assistance. 

OFCCP proposed reinstating CC-257 in February 2024, and in its Supporting Statement, indicated that the report would allow the Agency to “better identify if there are potential hiring or job assignment issues that warrant further investigation during a compliance evaluation.”

The new reporting requirement will include data on number of employees and trade employees’ hours worked by race and gender within each Standard Metropolitan Statistical Area (SMSA) or Economic Area (EA) each month. For contractors with employees working on multiple projects, either within a SMSA/EA or across several areas, gathering and preparing the relevant data each month may prove challenging. Contractors must also include whether the work performed is designated by OFCCP as a Megaproject.  Other requirements include the contractor’s unique entity identifier (UEI) or Data Universal Numbering System (DUNS) number, both of which OFCCP uses to identify entities doing business with the federal government, and a list of the federal agencies funding their projects.

The Agency published Frequently Asked Questions on its CC-257 Report landing page and intends to provide additional compliance assistance, including a webinar, in early 2025. 

Please reach out to your Jackson Lewis attorney with any questions or for assistance in preparing for this new reporting requirement.

Tags: construction contractors, discrimination, OFCCP
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Photo of Laura A. Mitchell Laura A. Mitchell

As co-leader of the firm’s ESG group, Laura Mitchell partners with her clients to evaluate, set, achieve and monitor their organizational culture and human capital goals. She focuses her practice on data analytics, including pay equity and other employee analytics, working side-by-side with…

As co-leader of the firm’s ESG group, Laura Mitchell partners with her clients to evaluate, set, achieve and monitor their organizational culture and human capital goals. She focuses her practice on data analytics, including pay equity and other employee analytics, working side-by-side with employers to build programs that benefit employees and create a stable, high-functioning workplace. Understanding that an inclusive, values-based culture provides a crucial competitive advantage in the modern workplace, Laura enjoys counseling companies on the development of proactive and equitable pay and diversity practices.

In Laura’s version of the reimagined workplace, attention to human capital issues, especially DEI and pay equity, would be the rule rather than the exception nationwide and she works with companies across all industries—both new and well-established multi-national organizations of all sizes—to realize this vision for her clients’ ongoing success. She helps clients understand all issues across the spectrum of their journey, helping to establish regular analyses as well as counseling organizations on implementation and compliance obligations, where applicable. Committed to putting her clients’ organizational goals first and foremost, Laura views herself as an extension of her clients’ team, responsible for providing proactive guidance and engaging in transparent, ongoing communication.

Laura also represents companies in OFCCP matters, preparing for and defending OFCCP audits, and counseling employers on issues stemming from OFCCP regulations. She personally oversees the development of hundreds of Affirmative Action Plans for clients each year and is intimately involved in the defense of OFCCP audits. Her approach to compliance is one of facilitation and conciliation while simultaneously advocating in the best interests of her clients.

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Photo of Lisa B. Marsh Lisa B. Marsh

Lisa B. Marsh is a principal in the Denver, Colorado, office of Jackson Lewis P.C. She represents management exclusively in all areas of employment law, focusing on affirmative action and EEO.

Lisa assists clients with the drafting of affirmative action plans, representing government…

Lisa B. Marsh is a principal in the Denver, Colorado, office of Jackson Lewis P.C. She represents management exclusively in all areas of employment law, focusing on affirmative action and EEO.

Lisa assists clients with the drafting of affirmative action plans, representing government and non-government contractors in Office of Federal Contract Compliance Programs (OFCCP) matters, preparing for and defending OFCCP audits, and counseling employers on issues stemming from OFCCP regulations.

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