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Friday, April 17, 2026

Federal Contractor Update - the Minimum Wage Final Rule, Updates to the Vaccination Mandate and More - Lexology

There have been several significant developments for federal contractors this month, including the issuance of the final rule implementing a higher minimum wage for certain federal contractors, further revisions to the vaccination mandate, an executive order requiring successor service contractors to offer employment to their predecessor’s employees, and a proposal to rescind the Trump administration’s religious exemption final rule.

Minimum Wage Final Rule. As we discussed in our April 2021 E-Update, President Biden signed Executive Order 14026 (EO) increasing the minimum wage rate applicable to government contractors and subcontractors to $15 an hour – a significant increase from the current rate of $10.95. The Department of Labor issued a proposed rule in July 2021 to implement the EO, and following an opportunity for public comment, has now issued a final rule. According to the DOL, the final rule:

  • Increases the hourly minimum wage to $15 an hour for workers performing work on or in connection with covered contracts, beginning Jan. 30, 2022.
  • Continues to index the federal contract minimum wage in future years to inflation.
  • Eliminates the tipped minimum wage for federal contract employees by 2024.
  • Ensures a $15 minimum wage for workers with disabilities performing work on or in connection with covered contracts.
  • Restores minimum wage protections to outfitters and guides operating on federal lands.

With limited exceptions, the Final Rule will apply to new contracts,...



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