OFCCP Reinstated CC-257 (Monthly Employment Utilization Report), and It is Due on April 15, 2025

What happened?

On November 25, 2024, the Office of Federal Contract Compliance Programs (OFCCP) announced reinstating the revised Monthly Employment Utilization Report (CC-257). 

Overview:

The OFCCP has reinstated the Monthly Employment Utilization Report (Form CC-257) for federal construction contractors and subcontractors, requiring them to submit monthly reports on employee counts and work hours starting in March 2025.

• The new Form CC-257, covering a full calendar month, is due by the 15th of the following month (or the next business day if this falls on a weekend or federal holiday). This requirement applies to employers with federal construction contracts or subcontracts exceeding $10,000.
• This aims to enhance enforcement and address employment discrimination in the construction industry.
• The agency also released the Reporting Periods Schedule so employers can program themselves and comply.

Additional Details:  

The new Form CC-257:

• Requires detailed company profile information, including contractor details, federal funding agencies, reporting period data, certifying official’s contact information, and the number of covered areas with projects.
• It seeks information on project type, entity type, total employee count, total work hours, and optional comments for each covered area.
• Form CC-257 must be submitted through a designated email (Report Form and Submission Methods). The first report, covering March 2025, is due on April 15, 2025.
  • The agency also released the Reporting Periods Schedule so employers can program themselves and comply.
• The OFCCP has underestimated the time required for submission, especially for those without electronic recordkeeping systems.
• Contractors should collaborate with HR and legal counsel to ensure compliance, potentially updating systems, hiring staff, or revising job duties.

Source References

• Form: Monthly Employment Utilization Report (CC-257)
• DOL OFCCP Monthly Employment Utilization Report (CC-257 Report)

Resources

• OFCCP Proposed Reinstatement With Change of Information Collection Requirements; Comment Request

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