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Proposed Rule and Guidance Issued for Implementing "Fair Pay and Safe Workplaces" Executive Order

Client Alert | 1 min read | 05.28.15

Today, the Obama Administration published the highly anticipated notice of proposed rulemaking (NPRM) and guidance for implementing the "Fair Pay and Safe Workplaces Executive Order," starting the clock on a 60-day notice and comment period. The NPRM and related guidance (available by PDF here and here and explained in more detail on our government contracts blog) would add onerous labor compliance reporting requirements for contractors and subcontractors on contracts valued over $500,000 (and on non-COTS subcontracts valued over $500,000), inject subjectivity into the contract award process through the addition of "Agency Labor Compliance Advisors" advising the CO with respect to responsibility determinations, limit contractors' right to arbitrate certain employment disputes, and add new "paycheck transparency" requirements for contractors.


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Client Alert | 7 min read | 12.17.25

CARB Proposes Regulations Implementing California GHG Emissions and Climate-Related Financial Risk Reporting Laws

After hosting a series of workshops and issuing multiple rounds of materials, including enforcement notices, checklists, templates, and other guidance, the California Air Resources Board (CARB) has proposed regulations to implement the Climate Corporate Data Accountability Act (SB 253) and the Climate-Related Financial Risk Act (SB 261) (both as amended by SB 219), which require large U.S.-based businesses operating in California to disclose greenhouse gas (GHG) emissions and climate-related risks. CARB also published a Notice of Public Hearing and an Initial Statement of Reasons along with the proposed regulations. While CARB’s final rules were statutorily required to be promulgated by July 1, 2025, these are still just proposals. CARB’s proposed rules largely track earlier guidance regarding how CARB intends to define compliance obligations, exemptions, and key deadlines, and establish fee programs to fund regulatory operations....

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