Executive Order 13672 is no longer in effect. President Trump revoked it on January 21, 2025, ending the federal contractor nondiscrimination protections it had added for sexual orientation and gender identity.1The White House. Ending Illegal Discrimination And Restoring Merit-Based Opportunity Workers are still protected against sexual orientation and gender identity discrimination, though, because the Supreme Court held in Bostock v. Clayton County that Title VII of the Civil Rights Act already covers both.2Supreme Court of the United States. Bostock v. Clayton County, 590 U.S. ___ (2020) What changed in 2025 is the enforcement machinery, not the underlying right.
What EO 13672 Did Before It Was Revoked
President Obama signed EO 13672 on July 21, 2014. It amended two older executive orders: EO 11478, which governs the federal civilian workforce, and EO 11246, which governed federal contractors.3The American Presidency Project. Executive Order 13672 – Further Amendments to Executive Order 11478, Equal Employment Opportunity in the Federal Government, and Executive Order 11246, Equal Employment Opportunity The practical effect was that companies with federal contracts worth more than $10,000 had to include sexual orientation and gender identity in their nondiscrimination policies, and the Office of Federal Contract Compliance Programs (OFCCP) enforced that requirement.4The White House Archives. President Obama Signs a New Executive Order to Protect LGBT Workers
What the January 2025 Revocation Did
The 2025 executive order, titled “Ending Illegal Discrimination And Restoring Merit-Based Opportunity,” did more than repeal EO 13672. It also revoked EO 11246 itself, dismantling the entire federal contractor nondiscrimination and affirmative action framework that had existed since 1965.1The White House. Ending Illegal Discrimination And Restoring Merit-Based Opportunity
The order directed OFCCP to stop promoting diversity, stop holding contractors responsible for affirmative action, and stop encouraging workforce balancing by race, color, sex, sexual preference, religion, or national origin. Contractors got a 90-day transition period. The order also requires contractors and grant recipients to certify that they don’t operate DEI programs the administration considers unlawful, and it treats that certification as material to payment under the False Claims Act.1The White House. Ending Illegal Discrimination And Restoring Merit-Based Opportunity
Are Workers Still Protected From Sexual Orientation and Gender Identity Discrimination?
Yes. The protection now rests on a statute rather than an executive order, which makes it more durable, not less.
On June 15, 2020, the Supreme Court ruled in Bostock v. Clayton County that firing a worker for being gay or transgender violates Title VII of the Civil Rights Act of 1964. Title VII prohibits discrimination “because of sex,” and the Court held that discrimination based on sexual orientation or gender identity is inherently a form of sex discrimination.5U.S. Equal Employment Opportunity Commission. Title VII of the Civil Rights Act of 1964
The difference in legal weight matters. An executive order can be revoked by any future president with a signature, as EO 13672 was. A Supreme Court interpretation of a federal statute can only be changed by Congress amending the law or by the Court reversing itself. Bostock applies to all employers with 15 or more employees, a much broader reach than EO 13672 ever had.
There is a limit worth knowing. Bostock answered whether firing someone for being gay or transgender is unlawful. It did not resolve how Title VII applies to sex-separated facilities, pronoun usage, or employer health coverage for gender-affirming care.6Congress.gov. Executive Order 11246 Those questions are still being contested in lower courts and through agency enforcement.
What Changed for Federal Contractor Employees
The legal rule against sexual orientation and gender identity discrimination still applies to federal contractors, because Bostock covers them the same as any other employer. What changed is who enforces the rule.
Under EO 13672, a contractor employee had two possible paths: an EEOC charge under Title VII, or an OFCCP complaint under EO 11246. OFCCP could also open compliance reviews of contractors on its own initiative, without waiting for a complaint. That proactive enforcement is gone for sexual orientation and gender identity claims. The path now is a Title VII charge with the Equal Employment Opportunity Commission, the same as for any private-sector worker.
OFCCP itself has not disappeared. It still enforces Section 503 of the Rehabilitation Act, which protects workers with disabilities, and the Vietnam Era Veterans’ Readjustment Assistance Act (VEVRAA), which protects certain veterans.7U.S. Department of Labor. Office of Federal Contract Compliance Programs Those programs remain intact.
What Changed for Federal Civilian Employees
EO 11478, the executive order covering the federal civilian workforce, was not revoked. But when EO 13672 fell, the 2014 amendment that had added “gender identity” to EO 11478’s protected categories fell with it. The current version maintained by the Department of Labor lists race, color, religion, sex, national origin, handicap, age, sexual orientation, and status as a parent. Gender identity is no longer a separately listed category.8U.S. Department of Labor. Executive Order 11478
Federal employees are still protected against gender identity discrimination through Title VII, which covers the federal government as an employer. The removal from EO 11478 is a policy signal, not a legal gap.
How to File a Complaint Now
The right path depends on your employer and the type of discrimination.
Private Employees, Including Federal Contractor Workers
File a charge of discrimination with the EEOC. Title VII applies to employers with 15 or more employees. The deadline is generally 180 days from the discriminatory act, extended to 300 days if your state or locality has its own fair employment agency with a worksharing agreement with the EEOC.
The EEOC investigates. If it finds reasonable cause, it tries conciliation. If that fails, the agency may sue on your behalf or issue a right-to-sue letter that lets you file your own lawsuit in federal court.
Federal Contractor Workers With Disability or Veteran Claims
OFCCP still takes these. File using Form CC-4 from the OFCCP website within 300 calendar days of the discriminatory act.9U.S. Department of Labor. Complaint Process10U.S. Department of Labor. Office of Federal Contract Compliance Programs Complaint Form CC-4 The form asks for your contact information, your employer’s legal name, the location where the discrimination occurred, the name of the highest-ranking official there, what happened and when, and any witnesses. You can submit it online, by mail, by fax, or by email to the OFCCP regional office for your area.
Federal Civilian Employees
Contact your agency’s EEO office within 45 calendar days of the discriminatory act to start counseling. After counseling, you can file a formal complaint with the agency. If you’re unhappy with the outcome, you can appeal to the EEOC or go to federal court.