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Change and uncertainty are among the words that come to mind when describing the government contracting industry in the early days of President Donald Trump’s second administration.

On February 21, 2025, a federal judge issued a nationwide preliminary injunction that partially prevents the Trump administration from enforcing its executive orders on diversity, equity and inclusion (“DEI”).

On January 21, 2025, President Donald Trump issued an Executive Order titled “Ending Illegal Discrimination and Restoring Merit-Based Opportunity” (the “Executive Order”), which significantly impacts not only requirements applicable to federal government contractors and subcontractors, but also could lead to private sector investigations or enforcement actions concerning Diversity, Equity, and Inclusion (“DEI”) initiatives — particularly those maintained by larger companies (whether privately held or publicly listed), regardless of whether they contract or subcontract with the government.

On June 18, 2024, the Department of the Treasury (the “Treasury”) and the Internal Revenue Service (the “Service”) issued (T.D. 9998) (the “Final Regulations”) regarding compliance with the prevailing wage and apprenticeship requirements (the “PWA Requirements”) impacting many of the clean energy tax credits introduced or expanded by the Inflation Reduction Act of 2022 (the “IRA”).

Attorneys from our Employment, Labor and OSHA and Tax groups discussed the prevailing wage and apprenticeship requirements in the Inflation Reduction Act.

Attorneys from our Employment, Labor and OSHA (ELO) and Tax Groups discussed the prevailing wage and apprenticeship requirements in the Inflation Reduction Act.