On March 14, 2025, President Trump issued an Executive Order entitled “Additional Rescissions of Harmful Executive Orders and Actions.” Of the 18 Executive Orders rescinded, noteworthy to employers is Executive Order 14026, “Increasing the Minimum Wage for Federal Contractors.”
President Biden issued Executive Order 14026 on April 27, 2021. It applied to:
- Procurement contracts for construction covered by the DBA;
- Service contracts covered by the SCA;
- Concessions contracts, including any concessions contract excluded from the SCA by the Department’s regulations at 29 CFR 4.133(b); and
- Contracts in connection with federal property or lands and related to offering services for federal employees, their dependents, or the general public.
Executive Order 14026 required contractors to pay a minimum wage of $15.00 per hour to employees who worked on or in connection with covered federal contracts. The updated wage rate has been in effect since January 30, 2022. The Executive Order also called for annual increases to the minimum wage based on inflation. As of January 1, 2025, the minimum wage for federal contractors rose to $17.75 per hour.
Though President Trump’s Executive Order rescinds President Biden’s, it does not explicitly revoke all preceding Executive Orders regarding minimum wage for federal contractors. Executive Order 13658, signed by President Obama in 2014, established a minimum wage of $13.30 per hour for covered contracts.
Employers are left to question whether they must pay a minimum wage of $13.30 per hour set by Executive Order 13658 or are subject to the current federal minimum wage of $7.25 per hour.
What Should Federal Contractors Do?
- Ensure Compliance with Contractual Obligations: Federal contractors should review their current contracts and follow established wage agreements.
- Consider Federal Prevailing Wage Laws: Federal contracts may still be subject to the Davis-Beacon Act or the McNamara-Ohara Service Contract Act.
- Be on the Lookout for Further Guidance from the Department of Labor: The DOL is expected to provide information regarding this recent Executive Order and its impact on federal contractors.
Keep in Mind
President Trump’s recent Executive Order will likely result in an update to the Federal Minimum Wage for Contractors poster. However, the exact nature of that update and when a new poster will be published remain to be determined.
LaborLawCenter will continue to monitor developments regarding the impact of this Executive Order on labor law posters to ensure you remain in compliance.
