The proposed rule would mandate new data collection and reporting requirements designed to restrict diversity, equity, and inclusion initiatives among federal contractors. The specific scope and implementation details of the information collection request remain unclear, though the coalition's letter signals significant compliance concerns. The administration has not yet responded to the coalition's demand for withdrawal.
Attorneys representing federal contractors should monitor this rule's progression closely. If finalized despite the multistate opposition, the requirements could trigger substantial new compliance obligations and reporting burdens. The coalition's coordinated pushback suggests the rule faces sustained legal and administrative pressure, but the administration's track record of advancing contested executive orders indicates the proposal may proceed regardless. Contractors should prepare for potential litigation and begin assessing their current DEI programs and data collection practices in anticipation of possible new federal mandates.