Quick Hits

• On March 14, 2025, President Trump issued EO 14236, “Additional Rescissions of Harmful Executive Orders and Actions,” revoking EO 14026, which had set a $15-per-hour minimum wage rate for federal contractors.
• The EO 13658 minimum wage rate (currently $13.30 per hour) is still in effect for certain covered contracts.
• EO 14026 and its implementing regulations are still subject to ongoing litigation.
• Federal contractors and subcontractors must continue to follow other federally mandated compensation requirements, including minimum wage rates and applicable wage determinations.

The $15-Per-Hour Minimum Wage Rate for Federal Contractors

EO 14026 generally required minimum wages for workers performing work on or in connection with contracts covered under the McNamara-O’Hara Service Contract Act; contracts covered under the Davis-Bacon Act; contracts in connection with federal property or lands and related to offering services for federal employees, their dependents, or the general public; and concession contracts. Because of yearly adjustments, in 2025, the applicable wage rate under EO 14026 was $17.75 per hour.

Since its issuance on April 27, 2021, EO 14026 has been under legal attack, primarily concerning whether its promulgation was within presidential authority under the Federal Property and Administrative Services Act (also known as the Procurement Act). The Fifth Circuit (within presidential authority), Ninth Circuit (not within presidential authority), and...

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