U.S. Equal Employment Opportunity Commission (“EEOC”) Chair Andrea Lucas said Wednesday that the agency’s new four-year strategic plan has secured final approval. This announcement is one of a series of shifts in EEOC focus under Lucas. So what do employers need to know about the current state of the EEOC, and where it is headed? Read more about it in the August employment law update:
The EEOC Under Andrea Lucas: What Employers Need to Know
Since President Trump designated Lucas as Chair of the EEOC, the agency has undertaken a significant shift in its enforcement priorities. While the EEOC’s mission remains the enforcement of federal anti-discrimination laws, Chair Lucas has emphasized what she describes as “evenhanded” enforcement, focusing on protecting all employees from unlawful discrimination regardless of race, sex, religion, or national origin.
The most significant development came in June 2026, when the EEOC adopted a new National Enforcement Plan for Fiscal Years 2025-2029, replacing the prior Strategic Enforcement Plan. The four-year plan provides a roadmap for the agency’s enforcement, litigation, outreach, and compliance efforts and offers employers valuable insight into where the EEOC intends to direct its resources.
A central theme of the Lucas EEOC is increased scrutiny of workplace policies or programs that make distinctions based on protected characteristics. The agency has signaled that it intends to examine diversity, equity, and inclusion (“DEI”) initiatives that may involve race- or sex-based preferences in hiring, promotions, internships, mentoring, leadership development, or other employment opportunities. According to the EEOC, Title VII prohibits discrimination against any individual, even when undertaken in pursuit of broader diversity objectives.
The agency has also elevated religious discrimination and accommodation claims as a key enforcement priority. Under Lucas’s leadership, the EEOC has pursued significant recoveries and litigation involving religious accommodations, including claims arising from workplace vaccination policies and other faith-based workplace conflicts. Employers should expect continued focus on accommodation requests, religious expression in the workplace, and allegations of religious harassment.
The Lucas EEOC has also proposed a significant change to federal workforce demographic reporting. In July 2026, the agency issued a proposed rule that would eliminate the long-standing EEO-1 reporting requirement and related demographic reporting obligations. While the proposal has not yet been finalized and covered employers must continue complying with existing reporting requirements, the initiative reflects the agency’s broader view that mandatory race- and sex-based workforce reporting is inconsistent with its current enforcement philosophy.
In addition, the new National Enforcement Plan highlights enforcement against overt discrimination in recruiting and hiring, job advertisements that discourage applicants based on protected characteristics, and practices that allegedly disadvantage employees based on race, sex, religion, or national origin. The plan also emphasizes prevention, education, voluntary compliance, and strategic litigation as complementary enforcement tools.
For employers, the changing enforcement landscape presents an opportunity to reassess workplace policies and practices. Companies should consider reviewing hiring and promotion procedures, DEI initiatives, accommodation processes, employee training programs, and anti-discrimination policies to ensure they are grounded in objective, job-related criteria.
Although EEOC priorities often change with administrations, the Lucas EEOC has made clear that it will pursue a different enforcement strategy than its recent predecessors. Employers who understand these priorities and proactively evaluate their practices will be better positioned to minimize risk and respond effectively to future agency scrutiny.
Jeff Burke is an attorney at MacElree Harvey, Ltd., working in the firm’s Employment and Litigation practice groups. Jeff counsels businesses and individuals on employment practices and policies, executive compensation, employee hiring and separation issues, non-competition and other restrictive covenants, wage and hour disputes, and other employment-related matters. Jeff represents businesses and individuals in employment litigation such as employment contract disputes, workforce classification audits, and discrimination claims based upon age, sex, race, religion, disability, sexual harassment, and hostile work environment. Jeff also practices in commercial litigation as well as counsels businesses on commercial contract matters.
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