Advancing Pay Equality Through Compensation Data Collection

This memorandum directs the Secretary of Labor to propose a rule within 120 days requiring federal contractors and subcontractors to submit summary compensation data broken down by sex and race to the Department of Labor. The goal is to improve enforcement of equal pay laws by identifying potential pay disparities and directing enforcement resources more efficiently.

Federal Register Open PDF 79 FR 20751

Impact dates

Aug 6, 2014
Proposed rule due from Secretary of Labor

Key directives

Propose rule within 120 days requiring federal contractors and subcontractors to submit summary compensation data by sex and race
Maximize efficiency by targeting enforcement toward entities with potential pay discrepancies
Minimize burden on contractors, especially small entities
Use data to encourage voluntary compliance and identify industry trends
Avoid new record-keeping requirements to extent feasible
Rely on existing reporting frameworks
Consider independent studies on compensation data collection

Who is ordered

Secretary of Labor · Department of Labor

Timeline

Immediate

Secretary of Labor directed to begin developing proposed rule

Near term (90d)

Proposed rule due within 120 days (by August 6, 2014)
DOL to consider efficiency, burden minimization, and voluntary compliance approaches

Long term

Potential new reporting requirements for federal contractors
Enhanced DOL enforcement of equal pay laws
Industry trend analysis on compensation disparities

Risks & tensions

Burden minimization goal may conflict with data robustness needed for effective enforcement
Small entity protections could limit data granularity
Reliance on existing reporting frameworks may constrain novel approaches
No guaranteed adoption timeline for final rule—only proposal required