EEOC Guidance to Federal Agencies Emphasizes Importance of Maintaining Proactive EEO Plans

August 26, 2025

What's New

The Equal Employment Opportunity Commission (EEOC) released FAQs reminding federal agencies that they are required to submit equal employment opportunity (EEO) plans in adherence with Management Directive 715 (MD-715).

MD-715 sets standards for agencies to implement EEO programs that are required by Title VII and Section 501 of the Rehabilitation Act. The goal of MD-715 is to ensure equal employment opportunities for applicants and employees in the federal workplace regardless of sex, national origin, color, religion, or disability.

Under MD-715, agencies must annually conduct a self-assessment of their workforce and employment practices to determine if there are barriers to EEO impacting their workforce. This includes analyzing workforce statistics broken down by race, national origin, sex, and disability status, as well as other information. MD-715 describes these statistics as an initial diagnostic tool, but identification of workplace barriers requires a thorough examination of all the circumstances.

MD-715 does not require preferences or quotas based on race or sex. Agencies must submit an annual report to the EEOC on the status of their EEO program.

What It Means

While E.O. 14173 eliminated female and minority affirmative action programs for federal contractors, federal agencies must continue to implement and submit EEO programs. The EEOC’s new guidance signals that the collection and analysis of workforce data remains a lawful method to monitor the workforce for unlawful employment practices.

What You Should Do

While MD-715 is specific to federal agencies, private sector employers can use its guidelines as a tool to develop proactive programs to identify and correct unlawful employment practices.

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