OFCCP Introduces New Monthly Reporting Requirements for Construction Contractors

The Office of Federal Contract Compliance Programs (OFCCP) has reinstated a monthly reporting requirement that will have a significant impact on federal construction contractors and subcontractors. Under the new mandate, covered businesses will need to submit Monthly Employment Utilization Reports (Form CC-257). The first report, covering March 2025, will be due on April 15, 2025, with all subsequent reports due on the 15th of each month.

For more information on the Monthly Employment Utilization Reports and their potential impact on your organization, please contact our Managing Counsel, Richard Liu, at contact@consultils.com.

Who Needs to Comply

The reporting requirement applies to contractors and subcontractors engaged in federally funded or federally assisted construction projects with contracts exceeding $10,000. These businesses must report on projects that fall within designated metropolitan or economic areas.

What Does the Report Include

The Monthly Employment Utilization Report requires contractors to provide detailed workforce data, including:

• Demographic information: Work hours and headcounts broken down by race, ethnicity, gender, and trade categories such as journey workers, apprentices, and laborers.

• Geographic details: Reports must reflect data for specific Standard Metropolitan Statistical Areas (SMSAs) or Economic Areas (EAs).

• Project details: Contractors must indicate whether the work is associated with an OFCCP-designated Megaproject.

• Company information: Unique Entity ID (UEI), Employer Identification Number (EIN), and information about the awarding federal agency.

  
  

The report must cover the previous calendar month and is due by the 15th of the following month. If the deadline falls on a weekend or holiday, submissions are due on the next business day.

Potential Penalties for Noncompliance

Noncompliance with the OFCCP’s new Monthly Employment Utilization Report requirements can result in serious penalties, including suspension or termination of federal contracts, debarment from future contracting opportunities, fines, and increased audits or compliance reviews. Contractors may also face legal enforcement actions or corrective orders for failing to submit accurate and timely reports. To avoid these consequences, contractors should prioritize compliance by implementing robust reporting systems and addressing potential risks proactively.

How Can Construction Contractors Prepare

To manage this new compliance obligation effectively, contractors should:

1. Evaluate coverage: Confirm whether your business falls under the reporting requirements.

2. Update internal systems: Ensure your HR systems can collect and organize data in the required format.

3. Establish workflows: Create a clear process for preparing and submitting reports, including assigning responsibility to specific team members.

4. Review utilization data: Analyze workforce trends with legal counsel to identify potential compliance risks.

5. Strengthen recruitment efforts: Use the data to evaluate outreach practices and improve workforce diversity.

   
   

For more information on the Monthly Employment Utilization Reports and their potential impact on your organization, please contact our Managing Counsel, Richard Liu, at contact@consultils.com.

Disclaimer: The materials provided on this website are for general informational purposes only and do not, and are not intended to, constitute legal advice. You should not act or refrain from acting based on any information provided here. Please consult with your own legal counsel regarding your specific situation and legal questions. 

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As Managing Partner at ILS, Richard Liu ranks among the leading U.S. attorneys in corporate, employment, and regulatory law. He is known for crafting legal strategies aligned with clients’ business objectives and advising Fortune 500 companies, startups, and executives on corporate transactions, financing, privacy, and employment matters across the technology, healthcare, and financial sectors.

Before founding ILS, Richard practiced at top defense firms, where he developed a reputation for anticipating risks and designing strategies that balance protection with growth. He has secured favorable outcomes in contract and intellectual property disputes, represented clients in state and federal courts, and is recognized for combining large-firm expertise with boutique-firm agility. Richard is also a frequent speaker at industry and legal conferences.

Email: contact@consultils.com | Phone