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Quick Hits
- Chief Financial Officers Act agencies and the U.S. Equal Employment Opportunity Commission must now submit Action Plans on Race and Ethnicity Data to OMB by March 28, 2026, extending the September 28, 2025, deadline that had been imposed when OMB released the SPD 15 revisions in March of 2024.
- OMB also extended the deadline to update federal information collections of race and ethnicity data to be consistent with the new standards. Such updates must be made as soon as possible, but the new deadline has been extended from March 28, 2029, to September 28, 2029.
Background
On March 28, 2024, OMB issued the first major revisions to SPD 15 since 1997. The revisions were the result of an extensive two‑year review process and were intended to produce more accurate and useful race and ethnicity data across the federal government. Among other changes, the 2024 update:
- combined race and ethnicity into a single question, allowing respondents to select multiple categories with which they identify.
- added “Middle Eastern or North African” (MENA) as a minimum reporting category, separate and distinct from “White.”
The revised minimum reporting categories are: “American Indian or Alaska Native,” “Asian,” “Black or African American,” “Hispanic or Latino,” “Middle Eastern or North African,” “Native Hawaiian or Pacific Islander,” and “White.” OMB has also reiterated that the race and/or ethnicity categories are not to be used as determinants of eligibility for participation in any federal program. OMB’s September 26, 2025, announcement made no changes to those updated race and ethnicity data standards.
Next Steps
The SPD 15 categories are widely used across federal agencies and often serve as a model for employers’ data collection, recordkeeping, and required government reporting (including federal EEO‑1s). Employers may wish to monitor forthcoming agency implementation guidance, including from the U.S. Equal Employment Opportunity Commission, and evaluate the potential impacts on their systems, forms, equal employment opportunity initiatives, and government reporting obligations. However, employers now have additional time before taking any action, given the two timeline extensions for SPD 15 implementation recently announced by OMB.
Ogletree Deakins’ Diversity, Equity, and Inclusion Compliance, Government Contracting and Reporting, and Workforce Analytics and Compliance Practice Groups will continue to track developments at the Office of Management and Budget and other federal agencies regarding SPD 15 and provide updates on the Diversity, Equity, and Inclusion Compliance, Employment Law, Government Contracting and Reporting, and Workforce Analytics and Compliance blogs.
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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