Form CC-257, the Monthly Employment Utilization Report, is not currently required. Executive Order 14173, signed January 21, 2025, revoked Executive Order 11246, the authority that made federal construction contractors file the form each month to report workforce hours by trade, race, and gender.1The White House. Ending Illegal Discrimination and Restoring Merit-Based Opportunity If you worked under the prior rules, or want to be ready in case reporting is restored, the sections below cover who was covered, what data went on the form, how it was submitted, and what enforcement looked like.
Why Filing Is Not Required Right Now
OFCCP had announced in 2024 that CC-257 would return as a routine monthly filing. The first covered period was March 2025, with reports due April 15, 2025, and then by the 15th of every following month.2Fisher Phillips. Federal Construction Contractors and Subcontractors Face New Reporting Requirements Executive Order 14173 overtook that plan. It revoked EO 11246 entirely and directed OFCCP to stop enforcing affirmative action obligations against federal contractors, and it gave contractors a 90-day window to wind down compliance with the old framework.1The White House. Ending Illegal Discrimination and Restoring Merit-Based Opportunity
Because CC-257 existed to enforce the equal employment goals set under EO 11246, the form has no current legal basis. A future administration could restore a similar requirement through new rulemaking or executive action, so monitoring OFCCP announcements is the safe habit.
Who the Form Applied To
Under the prior framework, CC-257 covered federal and federally assisted construction contractors and subcontractors subject to EO 11246 and 41 CFR Part 60-4. The filing trigger was a government contract or subcontract worth more than $10,000.3Government Publishing Office. Department of Labor Office of Federal Contract Compliance Programs Construction Contractors – Affirmative Action Requirements: Rescission of Reporting Requirements Both prime contractors and subcontractors on a covered project were included. What mattered was the contract’s value, not the size of the company.
Reporting scope was not limited to the federally funded job site. If your firm had electricians on a federal building, every electrician you employed in the same geographic area had to be counted. OFCCP defined those areas by Standard Metropolitan Statistical Area (SMSA) or Economic Area (EA), so your entire local workforce in each covered trade fell within the report.
Two narrow exemptions existed. Religious corporations, associations, and educational institutions were exempt from the equal opportunity provisions when hiring individuals of a particular religion for the organization’s work, though they had to follow every other requirement of the order. Contractors working on or near an Indian reservation could extend a publicly announced hiring preference to Indians living within commuting distance, provided the preference did not discriminate among Indians on the basis of religion, sex, sexual orientation, gender identity, or tribal affiliation.4Acquisition.GOV. 22.807 Exemptions
What Went on the Form
The data set was compact, but pulling it accurately took disciplined payroll systems.
Contractor and Reporting Period
The top of the form asked for the contractor’s name and address and the reporting month and year. A separate form was filed for each SMSA or Economic Area in which you operated. Geography was the organizing principle of the whole report.
Hours by Trade, Race, and Gender
The core of the form was a grid. For each construction trade (carpenters, electricians, ironworkers, laborers, masons, and so on), you reported total hours worked by all employees in that trade during the month across your workforce in the covered area, the hours worked by minority employees in that trade broken out by the federal racial and ethnic categories, and the hours worked by female employees in that trade.
From those inputs, you reported participation percentages: the share of total trade hours worked by minority employees and by female employees. The math was simple division. If your plumbers logged 2,000 hours in a month and 400 of those hours were worked by minority employees, the minority participation rate for plumbers that month was 20 percent. The hard part was clean inputs. Every hour had to be coded to the correct trade, demographic category, and geographic area, which mattered most for contractors running work across area boundaries.
Comparison to Participation Goals
OFCCP set minority and female participation goals for each geographic area and published them on its website.5Acquisition.GOV. Construction The CC-257 data let OFCCP compare your actual participation percentages against the goals for your area. A significant gap was the most common trigger for follow-up scrutiny.
How Submission Worked
Under the 2024 reinstatement plan, completed forms were due by the 15th of the month following each reporting period. If the 15th fell on a weekend or federal holiday, the deadline moved to the next business day.2Fisher Phillips. Federal Construction Contractors and Subcontractors Face New Reporting Requirements OFCCP’s Contractor Portal was the electronic submission platform.6U.S. Department of Labor. US Department of Labor to Open Online Portal April 1 for Federal Contractors, Subcontractors to Certify Affirmative Action Program Compliance Filings went to the OFCCP regional office overseeing the area where the work was performed.
Records to Keep
Contractors had to retain copies of filed reports and the supporting payroll documentation for at least two years from the date the record was made or the personnel action occurred, whichever was later. Smaller contractors, those with fewer than 150 employees or contracts under $150,000, could use a one-year retention period. If a complaint, compliance evaluation, or enforcement action was pending, all related personnel records had to be preserved until the matter was fully resolved, no matter how long that took.7GovInfo. 41 CFR 60-1.12 – Record Retention
What Happened When Filings Showed Problems
When OFCCP saw participation well below area goals, or when a contractor failed to file, the usual enforcement sequence began with a Show Cause Notice. That notice gave the contractor 30 days to explain why monitoring, enforcement proceedings, or other corrective action should not begin.8eCFR. Pre-Enforcement Notice and Conciliation Procedures OFCCP could issue that notice without a less formal warning first, so the first letter a contractor received could already carry real consequences.
If conciliation did not resolve OFCCP’s concerns, the agency could seek cancellation of existing federal contracts and subcontracts and pursue debarment, a formal ban on new federal contracts. Debarment for federal procurement violations generally lasts three years.9General Services Administration (GSA). Frequently Asked Questions: Suspension and Debarment For firms that depend on government work, that outcome was an existential risk, which is why most disputes resolved at conciliation.
Staying Ready If Reporting Returns
Filing is on hold, but the data systems that made CC-257 filings possible are worth maintaining. A few habits keep you positioned to file cleanly if a similar requirement comes back:
- Code every timecard entry with trade classification, demographic data, and project geographic area at the moment the hours are recorded, not from memory later.
- Reconcile payroll totals against trade-level breakdowns each month. Catching misallocated hours a month late is easy; catching them a year late is a forensic exercise.
- Know which SMSA or Economic Area each active project sits in, and allocate hours proportionally for workers who split time across areas.
- Collect self-identification data at hire and update it when employees voluntarily provide changes. Guessing demographics for reporting is inaccurate and a compliance risk on its own.