1. Home
  2. |Insights
  3. |OFCCP Moves To Eliminate Burdensome EO Survey And Offers "Grace Period" For Compliance With Internet Applicant Rule

OFCCP Moves To Eliminate Burdensome EO Survey And Offers "Grace Period" For Compliance With Internet Applicant Rule

Client Alert | 1 min read | 01.27.06

On January 20, 2005, the Office of Federal Contract Compliance Programs issued a notice of proposed rulemaking, finally moving to eliminate the burdensome EO Survey -- as the government contracting community has been urging for years. OFCCP is in the process of developing a new system for selecting audit targets.

The OFCCP has also announced that it will not delay implementation of the "Internet Applicant" rule, but will observe a 90-day "grace period." For 90 days following February 6, 2006, OFCCP will not cite a contractor for a purely technical recordkeeping violation for failure to comply with the Internet Applicant final rule, provided that the contractor (1) demonstrates that it is taking reasonable steps to update its systems to comply with the rule, including a projected date of compliance, and (2) collects and maintains records according to the established procedures consistent with OFCCP's recordkeeping requirements that preexisted the Internet Applicant final rule, i.e., 41 CFR 60-1.12.

Contacts

Insights

Client Alert | 3 min read | 08.03.26

New Jersey Takes Aim at Algorithmic and Surveillance Pricing: What Landlords and Retailers Need to Know About the FAIR Act and the Fair Price Protection Act

On July 20, 2026, New Jersey Governor Mikie Sherrill signed the Forbidding the Algorithmic Inflation of Rent (FAIR) Act into law, making New Jersey the fourth state to regulate algorithmic rent-setting practices. Three days later, on July 23, 2026, Governor Sherrill signed the Fair Price Protection Act, which targets “surveillance pricing”—the practice of using or collecting personal data about a user and using an algorithm or artificial intelligence to charge different consumers different prices for the same products. Together, these laws represent a significant expansion of New Jersey's consumer protection framework in the algorithmic pricing context....