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Federal-Sector EEO Complaint Process Would Undergo Sweeping Changes According to New EEOC Proposals

By Kevin Koronka, Sarah Vincent, Chengzhuo He & Nora Evans on September 25, 2026
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On August 28, 2026, the U.S. Equal Employment Opportunity Commission (EEOC) published a proposed rule that would substantially revise the federal-sector EEO complaint process under 29 C.F.R. Part 1614—the regulations governing how discrimination and retaliation complaints by federal employees and applicants are filed, investigated, and decided.

The proposed rule, which is not yet final (comments are due by September 28, 2026) would apply only to federal agencies, their employees, and applicants. The EEOC charge process for private-sector, state, and local government employers would not be affected.

Under the new rule

  • Direct filing would replace mandatory EEO counseling.
  • The employing federal agency, rather than an EEOC administrative judge, would make the initial decision on the merits of a complaint.
  • Administrative judge proceedings would become discretionary.
  • Administrative class complaints would be eliminated, and the EEOC would no longer certify or adjudicate classes, provide class notice, approve class settlements, or award relief to absent individuals.
  • Complaints would need to allege a plausible claim and contain enough factual detail to support it.
  • Settlement offers could limit attorney-fee recovery, and attorney fee requirements would become more detailed, with more specific standards for billing records, reasonable hours and rates, and fee reductions for unsuccessful or partially successful claims.
  • Transparency and accountability requirements would be expanded in several areas, including public disclosure, disciplinary reporting, complaint tracking, and others.

For a more detailed explanation of these proposed changes and what the EEOC rule would mean for employers, we encourage you to read the full legal update.

Photo of Kevin Koronka Kevin Koronka

Kevin focuses his practice on labor and employment. Frequently working with healthcare systems and providers, Kevin advises and defends employers on a wide range of issues, including high level investigations, leave and accommodation concerns, discrimination and harassment matters, non-competition agreements, reductions in force…

Kevin focuses his practice on labor and employment. Frequently working with healthcare systems and providers, Kevin advises and defends employers on a wide range of issues, including high level investigations, leave and accommodation concerns, discrimination and harassment matters, non-competition agreements, reductions in force and sensitive terminations.

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Photo of Sarah Vincent Sarah Vincent

Sarah helps clients proactively address labor and employment matters, creating an inclusive and welcoming culture for their employees. She focuses on preventative counsel, guiding clients through compliance with federal and state employment regulations.

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Photo of Chengzhuo He Chengzhuo He

Chengzhuo assists businesses with navigating the ever-evolving labor and employment landscape. He provides research, analysis, and counsel to help clients stay in compliance. Chengzhuo also has experience litigating employment disputes in state and federal courts, as well as before administrative agencies, including discovery,

…

Chengzhuo assists businesses with navigating the ever-evolving labor and employment landscape. He provides research, analysis, and counsel to help clients stay in compliance. Chengzhuo also has experience litigating employment disputes in state and federal courts, as well as before administrative agencies, including discovery, drafting position statements, mediation statements and motions.

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Photo of Nora Evans Nora Evans

Nora assists federal contractors with their diversity and pay equity obligations.

Nora examines contractors’ employment data, including datasets from companies with nationwide workforces of more than 150,000 individuals, performing advanced statistical work such as disparate impact analyses and regression modeling to advise clients

…

Nora assists federal contractors with their diversity and pay equity obligations.

Nora examines contractors’ employment data, including datasets from companies with nationwide workforces of more than 150,000 individuals, performing advanced statistical work such as disparate impact analyses and regression modeling to advise clients and ensure compliance. She analyzes areas such as employer hiring decisions, applicant pools, promotions, terminations, and overall workforce data compared to Census demographics. She also examines compensation across demographics to ensure compliance with equal pay laws, including the OFCCP’s Compensation Directive 2018-05, Title VII, the Equal Pay Act, and the Lilly Ledbetter Fair Pay Act.

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  • Posted in:
    Administrative and Regulatory, Employment & Labor
  • Blog:
    Labor and Employment Law Insights
  • Organization:
    Husch Blackwell LLP
  • Article: View Original Source

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