• Federal contractors must distinguish between contracts entered into before January 30, 2022 (subject to Executive Order (EO) 13658 and DOL’s annual indexed increases), and those entered into on or after that date, which were governed by EO 14026 prior to its revocation.
• Even though DOL is no longer enforcing EO 14026, contractors remain bound by existing contract clauses unless modified by the contracting officer and must comply with other applicable federal, state, and prevailing wage laws.
• The January 30, 2022, compliance date continues to determine which wage framework applies, whether DOL’s latest increase is triggered, and how legacy clauses and option exercises should be analyzed.

Since President Donald Trump revoked Executive Order 14026, which established a $15 per hour federal contractor minimum wage, contractors have faced uncertainty about minimum wage obligations. DOL’s recent annual minimum wage increase affecting certain federal contracts may add to the confusion. The key to understanding the current minimum wage landscape is recognizing that different rules apply depending on when a federal contract was entered into.

There have been two distinct federal contractor minimum wage regimes that affect contractors depending on the dates of their contracts: (1) an Obama-era contractor minimum wage rule, which remains in effect and is subject to annual inflation-based increases issued by DOL; and (2) the now-revoked Biden-era $15 minimum wage rule, which applied...

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