EEOC’s Draft Strategic Plan for FY 2026-2030 Comment Period Closes July 19, 2026  

Quick Hits

• The EEOC released a draft strategic plan for FY 2026–2030 on July 1, 2026, with public comments due by July 19, 2026.
• The draft narrows or removes several priorities carried over from the current FY 2022–2026 plan, most notably around systemic enforcement, the agency’s own diversity-related workforce commitments, and AI in hiring.
• Employers may wish to review the draft now, since it signals how the Commission intends to measure and prioritize its enforcement, outreach, and operational work through 2030.

Strategic plans are required for federal agencies under the Government Performance and Results Act Modernization Act. The EEOC’s strategic plan sets the framework the Commission uses to prioritize enforcement, outreach, and internal operations over a multiyear period. The draft retains the same three overarching goals as the current plan (enforcement, outreach and training, and organizational excellence) but revises several of the underlying performance measures and narrative commitments in ways employers may want to note.

Noteworthy Changes

The draft strategic plan continues to align with stated priorities, including advancing equal employment opportunity for all while fulfilling its “obligation to be impartial as it investigates charges in the private sector.” The draft strategic plan ties the Commission’s flagship systemic enforcement measure to a combined outcome: achieving “targeted equitable relief and at least $1 million in monetary relief” in 80 percent of systemic investigations where cause is found by the EEOC. The current strategic plan instead measures systemic enforcement through staffing and training commitments, including a requirement that every district maintain at least two dedicated Enforcement Unit systemic staff members. Employers involved in systemic pattern-or-practice disparate treatment matters may see a Commission that pursues fewer, more selective systemic cases while seeking larger recoveries in the cases it does bring. Employers may see more Commissioner’s charges, more requests for information and more class-based investigations.

The current strategic plan ties the agency’s own hiring and workforce practices to Executive Order 14035 and includes specific diversity, equity, inclusion, and accessibility commitments. The draft removes these references entirely from its organizational excellence goal, consistent with the Commission’s broader shift in posture away from diversity-related initiatives reflected in its recently adopted National Enforcement Plan.

The draft adds new language recognizing that generative AI will affect how applicants apply for jobs, how employers screen candidates, and how the agency itself operates. However, the draft does not include any corresponding performance measure or enforcement priority tied to AI-assisted employment decisions. Nevertheless, the EEOC has cautioned employers to understand and audit AI to ensure discrimination or other unlawful acts are not occurring as AI usage will not excuse liability. Employers using AI-assisted screening or selection tools may also wish to continue monitoring state and local requirements, several of which have moved into this space in the absence of active federal guidance.

The draft also narrows the current plan’s outreach commitments to vulnerable and underserved populations, replaces the U.S. Department of Labor’s Office of Federal Contract Compliance Programs with its Wage and Hour Division as a named outreach partner, and sets new numeric targets for reducing intake processing times. As the EEOC strives to reduce the time taken to process intake inquiries by 10 percent, employers may see quicker turnaround time on receiving notices of charges and charges.

Next Steps

The public comment period on the draft strategic plan closes July 19, 2026. Employers may wish to consider the following:

• Submit comments. Employers and trade associations with views on the draft’s enforcement priorities, particularly the revised systemic enforcement measure, have until July 19 to submit comments.
• Policy review in light of enforcement posture. Given the Commission’s continued emphasis on intentional discrimination theories, employers may want to review workplace policies, including diversity-related programs, for clear, documented, and consistently applied selection criteria and audit practices under protections of the attorney-client privilege to minimize legal risk.
• Continue monitoring AI-related developments. Because the draft plan does not fill the gap left by the Commission’s prior AI hiring guidance, employers using algorithmic or AI-assisted selection tools may wish to track state and local requirements directly and consider voluntary, proactive, and privileged audits for bias.
• Watch for the final plan. The Commission is expected to finalize the strategic plan after the comment period closes, and the final version may differ from the draft discussed here.

Ogletree Deakins’ Diversity, Equity, and Inclusion Compliance Practice Group, Government Contracting and Compliance Practice Group, and Workforce Analytics and Compliance Practice Group will continue to monitor developments and will provide updates on the Diversity, Equity, and Inclusion Compliance, Employment Law, Government Contracting and Compliance, and Workforce Analytics and Compliance blogs as additional information becomes available.

This article and more information on how the Trump administration’s actions impact employers can be found on Ogletree Deakins’ Administration Resource Hub.

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