Five Steps to Compliance with the Fair Pay and Safe Workplaces Final Rule
The much-anticipated so-called federal contractor “blacklisting” rules and guidance (“Final Rule” and “Guidance”) were published in the federal register on August 25, 2016. The Final Rule becomes effective on October 25, 2016 and imposes four new legal obligations on covered federal contractors, which will be phased in over the next year (starting as early as October 25, 2016). It is important to also note that this is being phased in via Federal Acquisition Regulation (“FAR”) solicitation and contract provisions. This means that the Final Rule “becomes effective” by beginning to appear in new solicitations issued on or after October 25, 2016. This should not dampen a company’s concern and speed of progressing through the steps below and determining and pursuing compliance, but it is critical to understand and follow the specific path of obligation.
