EEOC STRATEGIC 

ENFORCEMENT PLAN

2024–2028

U.S. EQUAL EMPLOYMENT OPPORTUNITY COMMISSION
U.S. Equal Employment Opportunity Commission 1 Strategic Enforcement Plan 2024–2028

 

 

Table of Contents 

EXECUTIVE SUMMARY 2 

I. GUIDING PRINCIPLES OF THE STRATEGIC ENFORCEMENT PLAN 5 

A. A Strategic Approach — focus on priorities to maximize the EEOC’s impact 5 

B. An Integrated Approach — collaboration, coordination, and consistency 5 

C. Accountability and Delivery of Results — taking ownership to achieve results and serve the 

public given available resources 6 

II. PRINCIPLE ONE: A STRATEGIC APPROACH TO STRENGTHEN ENFORCEMENT 7 

A. Focus on Strategic Impact to Leverage EEOC Resources Most Effectively 7 

B. Subject Matter Priorities for Fiscal Years 2024–2028 7 

C. Subject Matter Priorities 8 

D. District and Federal Sector-Specific Priorities 12 

E. Implementing SEP priorities 12 

F. Other Priorities 14 

III. PRINCIPLE TWO: INTEGRATING EFFORTS ACROSS EEOC 15 

A. Integrating Administrative Enforcement and Legal Enforcement in the Public and 

Private Sectors 15 

B. Integrating Federal Sector Activities 16 

C. Integrating Education and Outreach Activities 16 

D. Integrating Research, Data, and Analytics 17 

E. Collaborating with State and Local Fair Employment Practices Agencies and Tribal 

Employment Rights Offices 17 

F. Supporting Private Enforcement of the Federal Anti-Discrimination Laws 18 

G. Collaborating with Other Federal Agencies 18 

IV. PRINCIPLE THREE: DELIVERY OF RESULTS 19 

EFFECTIVE DATE 19 

ACKNOWLEDGMENTS 19 

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U.S. Equal Employment Opportunity Commission 2 Strategic Enforcement Plan 2024–2028

 

 

 

 

Executive Summary 

The U.S. Equal Employment Opportunity Commission (EEOC) was created by the landmark Civil 

Rights Act of 1964 in direct response to calls for racial and economic justice at the historic March on 

Washington for Jobs and Freedom. As the primary federal agency charged by Congress with enforc

ing laws against employment discrimination, the EEOC’s mission is to prevent and remedy unlawful 

employment discrimination and advance equal employment opportunity for all.

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1 

1 The EEOC enforces Title VII of the Civil Rights Act of 1964 (Title VII), which prohibits discrimination based on 

race, color, religion, sex (including pregnancy, childbirth, or related medical conditions; sexual orientation; 

and gender identity), and national origin; the Equal Pay Act of 1963 (EPA), which prohibits discrimination 

in compensation based on sex; the Age Discrimination in Employment Act of 1967 (ADEA), which prohibits 

discrimination based on age for people age 40 and older; Section 501 of the Rehabilitation Act of 1973 and 

Titles I and V of the Americans with Disabilities Act of 1990 (ADA), which prohibit discrimination based on 

disability; Title II of the Genetic Information Nondiscrimination Act of 2008 (GINA), which prohibits dis

crimination based on genetic information; and the Pregnant Workers Fairness Act (PWFA), which requires 

covered employers to provide reasonable accommodations to a qualified applicant’s or employee’s known 

limitations related to pregnancy, childbirth, or related medical conditions, unless the accommodation will 

cause the employer an undue hardship. 

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The purpose of the EEOC’s Strategic Enforcement Plan (SEP)2 is to focus and coordinate the agen

cy’s work over a multiple fiscal year (FY) period to have a sustained impact in advancing equal 

employment opportunity. The agency’s first 

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Strategic Enforcement Plan adopted for FY 2013–2016 

established subject matter priorities and strategies to integrate the EEOC’s private, public, and 

federal sector activities. In adopting the FY 2017–2021 SEP, the Commission reaffirmed its subject 

matter priorities with some modifications and additions. 

2 The SEP is a separate document from the agency’s Strategic Plan. The Government Performance and Results 

Act (GPRA) Modernization Act of 2010 requires the EEOC to develop and post a Strategic Plan on its public 

website every four fiscal years. The Strategic Plan explains the agency’s mission, operations, and processes 

for achieving general and long-term goals and objectives and approaches it will take to monitor its prog

ress. In contrast, the SEP sets forth subject matter priorities to guide all aspects of EEOC’s work to prevent 

and remedy unlawful employment discrimination. 

In developing the draft FY 2024–2028 SEP, the EEOC sought input from the public through a series of 

listening sessions and a dedicated email box. At the three public listening sessions, the EEOC heard 

from a total of 35 witnesses, including representatives from civil rights and workers’ rights organiza

tions, unions, employer and human resources representatives, scholars, and attorneys representing 

plaintiffs and defendants in employment discrimination matters.

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3 The EEOC received additional pub

lic comments through the dedicated email box. The EEOC then published the draft SEP in the 

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Federal 

Register for a 30-day public comment period and received a total of 48 comments.4 

3 See Appendix B for a full list of witnesses at the three public listening sessions. 

4 Draft Strategic Enforcement Plan, U.S. Equal Employment Opportunity Commission, 88 FR 1379 (Jan. 10, 2023). 

The EEOC is grateful to the public for its engagement and investment in the development of the 

SEP. The Commission carefully considered the thoughtful witness testimony and written submis

sions at the three listening sessions, the feedback provided through the dedicated email box, and 

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U.S. Equal Employment Opportunity Commission 3 Strategic Enforcement Plan 2024–2028

the comments submitted through regulations.gov. This unprecedented public input demonstrates 

the continued importance of EEOC’s work and the vitality of the agency’s mission. The suggestions 

received helped shape the final document and will inform the EEOC’s implementation of the SEP 

over the next five years. 

The final FY 2024–2028 SEP updates and refines the EEOC’s subject matter priorities to reflect 

progress in achieving the EEOC’s vision of fair and inclusive workplaces with equal opportunity for 

all, while also recognizing the significant challenges that remain in making that vision a reality. The 

brutal killings of George Floyd, Breonna Taylor, Adam Toledo, Tyre Nichols, and so many other peo

ple of color remain a painful reminder of systemic racism. The COVID-19 pandemic and its economic 

fallout disproportionately impacted people of color and other vulnerable workers, including those 

with disabilities, exposing and magnifying inequalities in our society. And high-profile incidents of 

bias and violence based on race, religion, national origin, and gender have impacted communities 

and workplaces across the country — including shootings targeting Black shoppers and workers 

in Buffalo, NY and Jacksonville, FL; Taiwanese churchgoers in Orange County, CA; patrons at an 

LGBTQI+ club in Colorado Springs, CO; and Jewish congregants in Pittsburgh, PA, among others. 

While these deep-rooted problems extend far beyond the workplace, the EEOC is committed to 

doing our part to combat systemic discrimination in employment. Addressing inequality in the 

workplace is a vital step in the broader fight for justice and equality. Every individual deserves the 

opportunity to make a living, support a family, and be respected in the workplace based on their 

skills and experience. 

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In implementing the SEP, the Commission can — and will — do more to combat employment dis

crimination, promote inclusive workplaces, and respond to the national call for racial and economic 

justice. Among other changes, this SEP: 

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• Expands the vulnerable and underserved worker priority to include additional categories of 

workers who may be unaware of their rights under equal employment opportunity laws, may 

be reluctant or unable to exercise their legally protected rights, or have historically been underserved by federal employment discrimination protections — such as people with intellectual 

and developmental disabilities; workers facing mental health related disabilities; individuals 

with arrest or conviction records; LGBTQI+ individuals; temporary workers; older workers; 

individuals employed in low-wage jobs, including teenage workers; and persons with limited 

literacy or English proficiency; 

• Refines the recruitment and hiring priority to include addressing policies and practices that 

limit access to on-the-job training, pre-apprenticeship or apprenticeship programs, tempto-hire positions, internships, or other job training or advancement opportunities based on 

protected status; 

• Recognizes employers’ increasing use of technology including artificial intelligence or ma

chine learning, to target job advertisements, recruit applicants, and make or assist in hiring and 

other employment decisions, practices, or policies; 

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U.S. Equal Employment Opportunity Commission 4 Strategic Enforcement Plan 2024–2028

• Updates the emerging and developing issues priority to include protecting workers affected 

by pregnancy, childbirth, or related medical conditions, including under the Pregnant Workers 

Fairness Act; employment discrimination associated with the long-term effects of the COVID-19 

pandemic, including Long COVID; and technology-related employment discrimination; and 

• Preserves access to the legal system by focusing on overly broad waivers, releases, nondisclosure agreements, or non-disparagement agreements. 

The SEP will help guide the EEOC’s work through all of the agency’s activities, including outreach, 

public education, technical assistance, enforcement, and litigation. Through its effective implemen

tation, the agency will continue to advance in the nation’s workplaces America’s foundational goals 

of equality and justice for all. 

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U.S. Equal Employment Opportunity Commission 5 Strategic Enforcement Plan 2024–2028

I. Guiding Principles of the Strategic 

Enforcement Plan 

In developing the Fiscal Year 2024–2028 SEP, the Commission relied on three guiding principles, 

adapted from the principles underlying the prior two SEPs: 

A. A Strategic Approach — focus on priorities to maximize the EEOC’s impact 

The EEOC will take a strategic approach to enforcement. A strategic approach empowers Com

mission staff throughout the agency to direct attention and resources to the specific priorities 

identified in this SEP, with the goal of positively influencing employer practices and promoting 

legal compliance. Strategic enforcement will enhance the Commission’s ability to prevent and 

eliminate unlawful employment practices, develop and clarify the law, and advance its mission 

and the public interest. A strategic approach includes proactive efforts to address SEP priority 

issues, including using Commissioner Charges and directed investigations as appropriate. 

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B. An Integrated Approach — collaboration, coordination, and consistency 

The EEOC will also ensure that its enforcement is integrated across the agency. An integrated 

approach means that the EEOC operates as one national law enforcement agency, while also 

appropriately reflecting local or regional priorities. This requires collaboration, coordination 

and communication between offices, staff, and program areas across the Commission, as well 

as consistent procedures in public-facing activities throughout the country. An integrated 

approach ensures that communications, outreach, education, training, research, and technolo

gy enhance and complement administrative and legal enforcement, policy development, and 

federal sector hearings, appeals, and oversight to advance the agency’s mission. An integrated 

approach also recognizes that, where appropriate, enforcement in the private, public, and fed

eral sectors should be coordinated and consistent. 

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Further, an integrated approach acknowledges that protecting workplace civil rights is a shared 

responsibility that extends beyond the EEOC. For example, the Department of Justice, Depart

ment of Labor, Fair Employment Practices Agencies (FEPAs), Tribal Employment Rights Offices 

(TEROs), and the private bar all play vital roles in preventing and remedying employment dis

crimination. As a result, it is important that the EEOC continue to collaborate with these entities, 

and coordinate across the federal government, to advance our shared missions and expand 

outreach to jobseekers, workers, and employers. 

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This SEP reaffirms that collaboration, coordination, and sharing of information within 

the EEOC and with our federal, state, local, and Tribal partners assist the Commission in 

operating strategically. 
U.S. Equal Employment Opportunity Commission 6 Strategic Enforcement Plan 2024–2028

C. Accountability and Delivery of Results — taking ownership to achieve results 

and serve the public given available resources 

As the primary federal agency entrusted by Congress with enforcing the nation’s workplace dis

crimination laws, the EEOC is accountable to the public it serves to ensure its resources are used 

strategically and effectively to enforce the law and support those most in need of its assistance. 

Accountability means taking ownership to achieve results and to deliver timely, consistent, and 

high-quality service to the public given available resources. 

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U.S. Equal Employment Opportunity Commission 7 Strategic Enforcement Plan 2024–2028

 

II. Principle One: A Strategic Approach to 

Strengthen Enforcement 

A. Focus on Strategic Impact to Leverage EEOC Resources Most Effectively 

To maximize the EEOC’s effectiveness as a national law enforcement agency, the Commis

sion must focus on those activities that have the greatest strategic impact. The Commission 

defines strategic impact as a significant effect on the development of the law or on promot

ing compliance across a large organization, geographic region, or industry. Relevant factors 

in determining strategic impact include the significance of a particular issue, the potential 

outcome, the number of individuals or employers affected, and the opportunity to prevent or 

deter future violations and to have broad and lasting impact in advancing equal employment 

opportunity. 

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Systemic investigations, resolutions, and lawsuits typically have strategic impact because they in

volve “pattern or practice, policy and/or class cases where the discrimination has a broad impact 

on an industry, profession, company, or geographic location.”

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5 The Commission reaffirms its com

mitment to a nationwide, strategic, and coordinated systemic program as one of the EEOC’s top 

priorities. The Commission also recognizes that an individual charge or case can have strategic 

impact, as defined above. Effective strategic enforcement includes a balance of individual and 

systemic cases, and of national and local issues, recognizing that each may have strategic impact 

in different and complementary ways. 

5 Systemic Task Force Report to the Chair of the Equal Employment Opportunity Commission, at 1. 

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The Commission’s identification of subject matter priorities under this SEP recognizes that 

focused and collective work on these areas will also have strategic impact. In addition, the Com

mission will continue to pursue matters and issues that are not identified as SEP priorities where 

EEOC enforcement will have a strategic impact in advancing equal employment opportunity. 

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B. Subject Matter Priorities for Fiscal Years 2024–2028 

The Commission’s goal in identifying agency-wide subject matter priorities is to ensure that 

the agency’s resources are focused on preventing and remedying discrimination and advanc

ing equal employment opportunity in circumstances where EEOC enforcement is most likely 

to achieve strategic impact. The EEOC will use all its tools, including enforcement (including 

investigations, settlements, and litigation), education and outreach, research, and policy devel

opment, to advance the agency’s priorities. 

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U.S. Equal Employment Opportunity Commission 8 Strategic Enforcement Plan 2024–2028

The Commission relied on the following criteria to identify subject matter priorities for this SEP: 

1. Issues that will have broad impact because of the nature and scope of the employment prac

tices addressed, the number of individuals impacted, or the employers or industries affected; 

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2. Issues affecting workers who may be unaware of their legal rights or reluctant or un

able to exercise their rights; 

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3. Issues involving developing areas of the law, where the Commission’s expertise is 

particularly valuable; 

4. Issues involving policies or practices that impede or impair full enforcement of federal 

employment discrimination laws; and 

5. Issues that may be best addressed by government action, including enforcement, based 

on the nature of the claim, the types of relief available, practical or legal impediments to 

private enforcement, or the Commission’s access to information, data, and research. 

C. SUBJECT MATTER PRIORITIES 

The following are the EEOC’s subject matter priorities for Fiscal Years 2024–2028: 

1. ELIMINATING BARRIERS IN RECRUITMENT AND HIRING 

The EEOC will focus on recruitment and hiring practices and policies that discriminate on 

any basis unlawful under the statutes EEOC enforces, including sex, race, national origin, 

color, religion, age, and disability. These include: 

• the use of technology, including artificial intelligence and machine learning, to target 

job advertisements, recruit applicants, or make or assist in hiring decisions where such 

systems intentionally exclude or adversely impact protected groups; 

• job advertisements that exclude or discourage certain protected groups from applying; 

• channeling, steering or segregating individuals into specific jobs or job duties based on 

protected characteristics; 

• policies and practices that limit access to on-the-job training, pre-apprenticeship or 

apprenticeship programs, temp-to-hire positions, internships, or other job training or 

advancement opportunities based on protected characteristics; 

• policies and practices that limit employees exclusively to temporary work on a basis 

prohibited by federal employment laws when permanent positions are available for 

which they are qualified; 

• reliance on restrictive application processes or systems, including online systems that 

are difficult for individuals with disabilities or other protected groups to access; and 
U.S. Equal Employment Opportunity Commission 9 Strategic Enforcement Plan 2024–2028

 

• the use of screening tools or requirements that disproportionately impact workers on a 

protected basis, including those facilitated by artificial intelligence or other automated 

systems, pre-employment tests, and background checks. 

The continued underrepresentation of women and workers of color in certain industries 

and sectors (for example, construction and manufacturing, high tech, STEM, and finance, 

among others), are also areas of particular concern, especially in industries that benefit from 

substantial federal investment. 

2. PROTECTING VULNERABLE WORKERS AND PERSONS FROM 

UNDERSERVED COMMUNITIES FROM EMPLOYMENT DISCRIMINATION 

The EEOC will focus on harassment, retaliation, job segregation, labor trafficking, 

discriminatory pay, disparate working conditions, and other policies and practices that 

impact particularly vulnerable workers and persons from underserved communities. With 

respect to employment discrimination, the Commission views the category of vulnerable 

workers as including: 

• immigrant and migrant workers and workers on temporary visas; 

• people with developmental or intellectual disabilities; 

• workers with mental health related disabilities; 

• individuals with arrest or conviction records; 

• LGBTQI+ individuals; 

• temporary workers; 

• older workers; 

• individuals employed in low wage jobs, including teenage workers employed in 

such jobs; 

• survivors of gender-based violence; 

• Native Americans/Alaska Natives; and 

• persons with limited literacy or English proficiency. 
U.S. Equal Employment Opportunity Commission 10 Strategic Enforcement Plan 2024–2028

 

 

 

 

 

These workers may be unaware of their rights under equal employment opportunity 

laws, may be reluctant or unable to exercise their legally protected rights, and/or have 

historically been underserved by federal employment discrimination protections. Factors 

such as immigration status, language barriers, education level, poverty and/or economic 

circumstances, geographic location, isolated work conditions, age, disability status, societal 

stigma, or lack of employment experience can make these workers particularly vulnerable to 

discriminatory practices or policies.6 

6 The agency’s 2013–2016 and 2017–2021 SEPs included sex discrimination against LGBTQI+ individuals as 

an emerging and developing issue. In Bostock v. Clayton County, 140 S. Ct. 1731 (2020), the Supreme Court 

affirmed — as the EEOC had held several years earlier — that Title VII of the Civil Rights Act of 1964 pro

hibits employment discrimination on the basis of sexual orientation or gender identity. Although Title VII’s 

coverage of sexual orientation and gender identity discrimination has been settled by the Supreme Court 

and thus is no longer an emerging legal issue, preventing and remedying discrimination against LGBTQI+ 

individuals remain a key priority for the EEOC, as such individuals are often vulnerable and have historical

ly been underserved. The Commission has therefore included LGBTQI+ individuals in the vulnerable and 

underserved worker priority. 

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To implement this priority, district offices and the agency’s federal sector program will 

identify vulnerable workers and underserved communities in their districts or within the 

federal sector for focused attention, based on their assessment of how the EEOC can most 

effectively utilize its resources to address issues of concern for these groups. For example, 

employment discrimination against Native Americans/Alaska Natives, indigenous people 

from Latin America, agricultural workers, workers on temporary visas, or individuals with 

arrest or conviction records might be areas of focus as part of this priority. 

3. ADDRESSING SELECTED EMERGING AND DEVELOPING ISSUES 

The EEOC will continue to prioritize issues that may be emerging or developing, including 

issues that involve new or developing legal concepts or topics that are difficult or complex. 

The agency is uniquely suited to address these issues given the EEOC’s research, data col

lection, receipt of charges in the private and public sectors, adjudication of complaints and 

oversight in the federal sector, and ongoing engagement with stakeholders. 

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Because of the nature of this priority category, the Commission may add or remove issues 

through interim amendments to the SEP. The following issues currently fall within this 

category: 

a) Qualification standards and inflexible policies or practices that discriminate 

against individuals with disabilities 

b) Protecting workers affected by pregnancy, childbirth, or related medical condi

tions under the Pregnancy Discrimination Act (PDA) and the Pregnant Workers 

Fairness Act (PWFA), as well as pregnancy-related disabilities under the Americans 

with Disabilities Act (ADA) 

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c) Addressing discrimination influenced by or arising as backlash in response to 

local, national, or global events, including discriminatory bias arising as a result of 

recurring historical prejudices 
U.S. Equal Employment Opportunity Commission 11 Strategic Enforcement Plan 2024–2028

 

 

 

 

 

 

 

For example, discrimination, bias, and hate directed against religious minorities 

(including antisemitism and Islamophobia), racial or ethnic groups, and LGBTQI+ 

individuals may fall within this subcategory. The discriminatory practices or affect

ed groups or individuals may change during the time period covered by this SEP. 

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d) Employment discrimination associated with the long-term effects of the COVID-19 

pandemic, including Long COVID 

e) Technology-related employment discrimination 

The EEOC will focus on employment decisions, practices, or policies in which covered 

entities’ use of technology contributes to discrimination based on a protected character

istic. These may include, for example, the use of software that incorporates algorithmic 

decision-making or machine learning, including artificial intelligence; use of automated 

recruitment, selection, or production and performance management tools; or other existing 

or emerging technological tools used in employment decisions. 

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4. ADVANCING EQUAL PAY FOR ALL WORKERS 

The EEOC will continue to focus on combatting pay discrimination in all its forms — on 

the basis of sex under the Equal Pay Act and Title VII, on other protected bases covered 

by federal anti-discrimination laws, including race, national origin, disability, and age, 

and at the intersection of protected bases. Because many workers do not know how their 

pay compares to their coworkers’ and, therefore, are less likely to discover and report 

pay discrimination, the Commission will continue to use directed investigations and 

Commissioner Charges, as appropriate, to facilitate enforcement. 

The Commission will also focus on employer practices that may impede equal pay or con

tribute to pay disparities and may lead to violations of statutes the Commission enforces, 

such as pay secrecy policies, discouraging or prohibiting workers from asking about pay or 

sharing their pay with coworkers, and reliance on past salary history or applicants’ salary 

expectations to set pay. 

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5. PRESERVING ACCESS TO THE LEGAL SYSTEM 

The EEOC will focus on policies and practices that limit substantive rights, discourage or pro

hibit individuals from exercising their rights under employment discrimination statutes, or 

impede the EEOC’s investigative or enforcement efforts. For example, this priority includes 

policies or practices that deter or prohibit filing charges with the EEOC or cooperating freely 

in EEOC investigations or litigation. Specifically, the EEOC will focus on: 

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a) overly broad waivers, releases, non-disclosure agreements, or non-disparagement 

agreements; 

b) unlawful, unenforceable, or otherwise improper mandatory arbitration provisions; 

c) employers’ failure to keep applicant and employee data and records required by 

statute or EEOC regulations; and 
U.S. Equal Employment Opportunity Commission 12 Strategic Enforcement Plan 2024–2028

 

 

d) retaliatory practices that could dissuade employees from exercising their rights 

under employment discrimination laws. This subcategory focuses on retaliatory 

practices that detrimentally impact or otherwise affect employees beyond those 

engaging in protected activity. 

6. PREVENTING AND REMEDYING SYSTEMIC HARASSMENT 

Harassment, both in-person and online, remains a serious issue in our nation’s workplaces. 

Over 34 percent of the charges of employment discrimination the EEOC received between FY 

2018 and FY 2022 included an allegation of harassment, and harassment charges increased in 

FY 2022.7 In the federal sector, 47 percent of appeals received between FY 2018 and FY 2022 

included an allegation of harassment, and the total number of harassment charges increased 

in FY 2022. The EEOC will continue to focus on combatting systemic harassment in all forms 

and on all bases — including sexual harassment and harassment based on race, disability, 

age, national origin, religion, color, sex (including pregnancy, childbirth, or related medical 

conditions, gender identity, and sexual orientation) or a combination or intersection of any of 

these. With respect to charges and litigation, a claim by an individual or small group may fall 

within this priority if it is related to a widespread pattern or practice of harassment. 

7 Total harassment charges increased from 21,270 in FY2021 to 24,430 in FY2022. Sexual harassment charges 

increased from 5,581 in FY2021 to 6,201 in FY2022 and race harassment charges increased from 7,755 in 

FY2021 to 8,524 in FY2022. See 

. For federal agencies, total harassment charges increased from 6,541 in FY2021 to 

7,590 in FY2022. 

Enforcement and Litigation Statistics | U.S. Equal Employment Opportunity 

Commission (eeoc.gov)

To combat this persistent problem, the EEOC will continue to focus on strong enforcement 

with appropriate monetary relief and targeted equitable relief to prevent future harassment. 

The EEOC will also focus on promoting comprehensive anti-harassment programs and 

practices, including training tailored to the employer’s workplace and workforce, using 

all available agency tools, including outreach, education, technical assistance, and policy 

guidance. 

D. District and Federal Sector-Specific Priorities 

The subject matter priorities set forth in the SEP are intended to be broad enough to encompass 

the needs and priorities of the EEOC’s field offices across the country and the federal sector. Nev

ertheless, district offices and the Office of Federal Operations may designate additional subject 

matter priorities for focused attention as needed to address unique or local issues. 

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E. Implementing SEP priorities 

To maximize the agency’s effectiveness, the EEOC’s resources must align with its priorities. The 

following guidelines are intended to ensure that cases and matters that advance SEP subject 

matter priorities, as well as other charges and cases that have strategic impact, receive the 

attention and resources needed to advance equal opportunity and prevent and remedy dis

crimination in the workplace. 

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U.S. Equal Employment Opportunity Commission 13 Strategic Enforcement Plan 2024–2028

The EEOC will use SEP priorities to inform charge prioritization, selection of litigation and 

amicus briefs, federal sector enforcement, and all other activities across the agency including 

guidance, outreach, and research. The agency will also continue to pursue matters and issues 

that are not identified as SEP priorities where EEOC enforcement will have a strategic impact. 

1. Charge Prioritization 

Since at least 1995, the Commission has categorized charges for priority handling based 

on the likelihood of an investigation resulting in a finding of reasonable cause to believe 

that discrimination has occurred. Charge prioritization is a continuous process that occurs 

throughout the life of a charge; in each case, the investigation should be appropriate to 

the charge, taking into account the EEOC’s resources.8 Because the demand for the EEOC’s 

services still far exceeds the agency’s resources, the Commission must continue to strategi

cally leverage its finite resources to best serve the public and most effectively achieve the 

goals of the statutes it is charged with enforcing. Clearly defined priorities enable the EEOC 

to focus resources where government enforcement is most needed and can deliver the 

greatest impact. Accordingly, a potentially meritorious charge that raises an SEP priority or 

is likely to have strategic impact should receive priority in charge handling consistent with 

longstanding procedures. 

8 Priority Charge Handling Procedures, at 2 (June 1995). 

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2. Litigation Program 

The EEOC’s litigation program is a critical tool in the agency’s efforts to prevent and remedy 

unlawful employment discrimination and enforce civil rights in the workplace. In developing 

and selecting cases for litigation, the Office of General Counsel should prioritize meritorious 

cases that raise SEP priorities or are otherwise likely to have strategic impact. SEP priorities 

should also be considered in selecting cases for amicus curiae participation. 

The Commission encourages the General Counsel, District Directors, and Regional Attorneys 

to continue to collaborate with the private bar, industry liaison groups, non-profit organiza

tions, the Department of Justice, the Office of Federal Contract Compliance Programs, and 

the EEOC’s other federal, state, and local partners to ensure efficient coordination and sup

port their critical roles in protecting civil rights and ensuring compliance with employment 

discrimination laws. 

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3. Systemic Program 

Eradicating systemic discrimination has long been one of the EEOC’s top priorities, as un

derscored in the Systemic Task Force Recommendations of 2006, and reaffirmed in EEOC’s 

2016 review of the Systemic Program, “

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Advancing Opportunity — A Review of the Systemic 

Program of the U.S. Equal Employment Opportunity Commission,” and in each of the EEOC’s 

prior Strategic Enforcement Plans. The Commission once again reaffirms its commitment 

to the agency’s systemic program as fundamental to advancing the agency’s mission to 

prevent and remedy unlawful employment discrimination and advance equal opportunity 

for all. 
U.S. Equal Employment Opportunity Commission 14 Strategic Enforcement Plan 2024–2028

The agency will use the SEP priorities to guide the types of systemic investigations and 

cases to be pursued by the Commission at the national and local levels. Meritorious systemic 

charges and cases that raise SEP priorities should be given precedence over other cases to 

maximize the EEOC’s strategic impact. 

4. Alternative Dispute Resolution Program 

As the Strategic Enforcement Plan focuses resources on SEP priorities, Alternative Dispute 

Resolution (ADR) continues to be an important tool to provide service to the public and pro

mote timely resolution of discrimination charges against private, state, and local employers 

as well as complaints in the federal sector. The EEOC’s ADR program provides an opportunity 

for individuals filing charges or complaints of discrimination and employers to convene and 

discuss their respective positions with a neutral mediator. Successful mediations resolve 

charges and complaints early in the process, benefiting both workers and employers and 

conserving agency resources. 

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Independent studies of the EEOC’s mediation program report 

that participants view the program as highly effective, fair, and neutral, and expressed 

strong satisfaction with the process. The studies also found “near unanimity” in participants’ 

willingness to participate in the EEOC’s mediation program in the future. The Commission 

encourages ADR as an effective and efficient tool to resolve charges and complaints of 

discrimination. 

5. Federal Sector Hearings, Appeals, Oversight and Outreach 

The SEP priorities serve several purposes in the federal sector. First, cases that raise these 

priorities alert the Commission to the potential need for more extensive legal analysis in 

federal sector appellate decisions, which also could serve as persuasive authority on related 

issues in the federal courts. Second, the EEOC’s federal sector program is responsible for out

reach and training to support oversight of federal agency EEO programs. Third, identifying 

SEP priorities in hearings and appeals provides the EEOC with information about trends in 

legal or factual issues to support federal sector outreach, training, compliance reviews, and 

program evaluations. 

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F. Other Priorities 

Chair initiatives should complement, rather than replace, SEP priorities. 
U.S. Equal Employment Opportunity Commission 15 Strategic Enforcement Plan 2024–2028

 

 

III. Principle Two: Integrating Efforts 

Across EEOC 

As noted above, the Commission is committed to an integrated approach at the agency that pro

motes collaboration, coordination, and information sharing throughout the agency, beginning with 

the following requirements: 

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A. Integrating Administrative Enforcement and Legal Enforcement in the Public 

and Private Sectors 

Generally, the Commission has a statutory responsibility to receive, investigate, and attempt to 

resolve charges of discrimination filed against private sector and state and local employers.9 If 

the Commission determines there is reasonable cause to believe discrimination has occurred, 

the agency attempts to end the alleged unlawful practice through an informal and confidential 

process known as conciliation. If conciliation is unsuccessful, the Commission has the author

ity to sue private entities under Title VII, Title I of the ADA, the PWFA, and Title II of GINA. (The 

Department of Justice has public sector litigation authority under these statutes). The EEOC has 

the authority to sue both public and private entities under the Equal Pay Act and the ADEA. 

9 The EEOC does not have a statutory duty to investigate under the Equal Pay Act or the Age Discrimination in 

Employment Act and the Equal Pay Act does not require conciliation. 

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Having a seamless, integrated effort between the enforcement unit staff who investigate and 

conciliate discrimination charges and the legal staff who litigate cases on behalf of the Commis

sion is critical for the agency’s work to have significant impact and to provide excellent service 

to the public. To establish a baseline of consistency across all offices, the SEP requires: 

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1. Legal-Enforcement Interaction 

The Commission reaffirms the importance of regular and meaningful consultation and col

laboration between investigative and legal staff throughout investigations and conciliations. 

Effective administrative and court enforcement of workplace civil rights laws requires that 

the EEOC’s investigative and legal staff communicate and work together to best achieve the 

EEOC’s mission. 

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The Commission commends the collaboration between administrative and legal enforce

ment that exists in many offices and encourages headquarters and field office legal and 

investigative staff to continue to enhance these important partnerships. 

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U.S. Equal Employment Opportunity Commission 16 Strategic Enforcement Plan 2024–2028

2. Coordination of Systemic Enforcement 

Effective systemic enforcement requires communication and collaboration between the 

EEOC’s legal and enforcement units, between headquarters and the field, and across EEOC 

districts. The Commission encourages cross-district and agency-wide collaboration, con

sultation, and strategic partnerships to avoid duplicating efforts, promote efficiency, and 

maximize the impact of the EEOC’s systemic program. 

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B. Integrating Federal Sector Activities 

The goal of advancing equal opportunity applies in the federal and private sectors, as does the 

principle of integrated strategies. The Commission encourages the Office of Federal Opera

tions and the Office of Field Programs to continue enhanced communication and coordination 

within the federal sector. The EEOC’s federal sector activities includes its hearings program; 

appellate program; oversight; and education, training, and outreach programs. It is critical that 

the Commission leverage its authority and integrate its activities in the federal sector to help 

federal agencies achieve and maintain “Model EEO Program” status, as mandated by Congress. 

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C. Integrating Education and Outreach Activities 

Clear and accessible information is critical to preventing discrimination, promoting compliance 

with federal EEO laws, and informing individuals of their rights. Investigations, conciliations, 

and litigation are only some of the means that the EEOC uses to fulfill its mission and vision. 

Education and outreach programs, as well as regulations, guidance, and training materials, are 

also cost-effective law enforcement tools because they promote understanding of the law and 

voluntary compliance. To ensure the public has easy access to information and technical assis

tance from the EEOC and that the agency is fully integrating the SEP priorities into its education 

and outreach efforts, the Commission adopts the following strategies: 

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• Providing up-to-date, accessible guidance on the requirements of employ

ment discrimination laws 

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The EEOC’s FY 2022–2026 Strategic Plan recognizes the importance of preventing 

employment discrimination and advancing equal employment opportunity through 

outreach and education. In furtherance of this important objective, the EEOC is focused on 

efforts to ensure that members of the public are aware of employment discrimination laws 

and have access to the EEOC’s services, that jobseekers and workers know their rights, and 

that employers, federal agencies, unions, and staffing agencies know their responsibilities 

under these laws and have the information and resources to advance equal employment 

opportunity, prevent discrimination, and effectively resolve EEO issues. The EEOC is focused 

on developing and updating its regulations, guidance, training materials, and other 

information it provides to the public to ensure that applicants, employees, employers, and 

members of the public are aware of their rights and responsibilities. 
U.S. Equal Employment Opportunity Commission 17 Strategic Enforcement Plan 2024–2028

 

To fully integrate education and outreach activities with the EEOC’s SEP priorities, the 

agency commits to leveraging technology, analytics, the EEOC’s language access plan, and 

innovative outreach strategies to provide the public, including hard to reach communities 

and those who lack ready access to EEOC resources, greater access to information about 

their rights and responsibilities. The EEOC will also provide technical assistance to underserved segments of the employer community, including small, new, and disadvantaged 

businesses. By using these additional resources, the agency will be better equipped to 

ensure that information and training provided to the public advances the agency’s priorities. 

• Promoting promising practices to help prevent discrimination in the 

workplace 

The Commission commits to integrating the SEP priorities into its education and outreach 

activities by promoting promising practices for employers to help prevent discrimination 

from occurring. These resources and leading practices will enable all employers to adopt 

policies and practices to help prevent employment discrimination and advance equal 

employment opportunity. 

To further those objectives, the EEOC will support employer efforts to implement lawful and 

appropriate diversity, equity, inclusion, and accessibility (DEIA) practices that proactively 

identify and address barriers to equal employment opportunity, help employers cultivate a 

diverse pool of qualified workers, and foster inclusive workplaces. 

D. Integrating Research, Data, and Analytics 

Collecting and analyzing data is central to the EEOC’s enforcement and educational efforts. 

The EEOC recognizes the importance of data-driven decision-making and the transformative 

role data can have to make the EEOC more effective in advancing its priorities and serving the 

public. Since 2018, with the creation of the Office of Enterprise Data and Analytics (OEDA), the 

Commission has made significant investments in upgrading its ability to collect and use quality 

data. The EEOC will continue to build its capacity to provide mission-critical evidence and better 

integrate its information and data policy with the agency’s SEP priorities. 

E. Collaborating with State and Local Fair Employment Practices Agencies and 

Tribal Employment Rights Offices 

State and local Fair Employment Practices Agencies (FEPAs) and Tribal Employment Rights 

Offices (TEROs) are critical partners in the EEOC’s enforcement of equal employment oppor

tunity laws. The EEOC contracts with FEPAs nationwide to process about 35,000 employment 

discrimination charges each year. Through a dual-filing process made possible by work-shar

ing agreements, the agencies avoid duplicating work and make it easier for the public to file 

charges of discrimination. The EEOC and FEPAs also collaborate in various activities, including 

investigations, internal training, and outreach events. Similarly, the EEOC partners with TEROs 

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U.S. Equal Employment Opportunity Commission 18 Strategic Enforcement Plan 2024–2028

to promote equal employment opportunity on or near Native American/Alaska Native res

ervations or tribal lands. The TEROs also collaborate with the EEOC by completing interview 

questionnaire forms for potential charging parties and forwarding them to EEOC field offices. 

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The EEOC district offices, FEPAs, and TEROs will continue to identify areas for collaboration 

based on the SEP priorities and the needs in their specific jurisdictions to benefit the public. 

These areas of collaboration may include, but are not limited to, outreach events and listening 

sessions with stakeholders to discuss SEP priorities. The district offices will review the effective

ness of the joint activities on an annual basis and adjust as needed. 

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F. Supporting Private Enforcement of the Federal Anti-Discrimination Laws 

The Commission has an obligation to ensure meaningful legal protections for individuals while 

also effectively using its resources to have the greatest impact. Given its limited resources, the 

EEOC litigates only a small percentage of reasonable cause findings where conciliation efforts 

have failed. EEOC staff may share with the parties, to the extent permitted under the law and as 

appropriate, information to facilitate swift enforcement and early resolution of charges. To bet

ter assist individuals whose charges are not settled or litigated by the EEOC, district offices will 

provide information to individuals who seek to contact employment law attorneys for further 

assistance. 

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G. Collaborating with Other Federal Agencies 

The EEOC is the government’s lead agency on equal employment opportunity. However, as 

previously noted, the Department of Justice, the Department of Labor, and other federal agen

cies also play important roles in enforcing laws prohibiting employment discrimination. The 

Commission will continue to collaborate with our sister agencies to further our mission. 

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U.S. Equal Employment Opportunity Commission 19 Strategic Enforcement Plan 2024–2028

IV. Principle Three: Delivery of Results 

To ensure that the EEOC is achieving results in accordance with the priorities set forth in the SEP, 

program offices will report progress to the Commission at semi-annual briefings as follows: 

• The Office of Field Programs will report on enforcement activities and outreach, 

education, and training involving SEP priorities. 

• The Office of General Counsel will report on litigation involving SEP priorities. 

• The Office of Federal Operations will report on federal sector activities involving 

SEP priorities. 

The midyear briefing will cover the first and second quarters of the fiscal year, and the annual brief

ing will cover all four quarters. 

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Effective Date 

The SEP is effective the day following approval by the Commission and will remain in effect until 

superseded, modified or withdrawn by vote of a majority of members of the Commission. 

Acknowledgments 

The Commission extends its thanks to everyone who participated in the development of the draft 

SEP, especially the members of the EEOC Strategic Planning Work Group and the SEP Subgroup. The 

Commission also thanks the EEOC staff who provided feedback on the SEP, the nearly three dozen 

witnesses who addressed the Commission at the three public listening sessions, and members of the 

public who submitted comments on the SEP through the dedicated inbox and via regulations.gov. 
U.S. Equal Employment Opportunity Commission 20 Strategic Enforcement Plan 2024–2028

Appendix A — EEOC National Strategic Enforcement 

Plan Subgroup 

Leadership 

Elizabeth Fox-Solomon, Chief of Staff, Office of the Chair (Chair) 

Thomas Colclough, Director, Field Management Programs, Office of Field Programs (Co-Chair) 

Members 

Carlton Hadden, Director, Office of Federal Operations 

Colleen Hampton-Lyster, Director, Advice, Audits, and External Reports Division, Office of Communi

cations and Legislative Affairs 

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Mandana Massjouni, Director, Enterprise Application and Innovation Division, Office of the Chief 

Information Officer 

Andrew Rogers, Chief Counsel, Office of Commissioner Lucas 

Jerome Scanlon, Assistant General Counsel, Office of General Counsel 

Lisa Schnall, Senior Attorney-Advisor, Office of Legal Counsel 

Ex Officio Members 

Cynthia G. Pierre, Ph.D., Chief Operating Officer and Chief Performance Improvement Officer, Office 

of the Chair 

Brett Brenner, Acting Deputy Chief Operating Officer, Office of the Chair 

Key Staff Support 

Antoinette Eates, Chief of Staff, Office of the Vice Chair 

Lucila Rosas, Attorney Advisor, Office of the Chair 
U.S. Equal Employment Opportunity Commission 21 Strategic Enforcement Plan 2024–2028

Appendix B — Strategic Enforcement Plan Public 

Listening Sessions 

SEP Listening Session 1 

Advancing Racial and Economic Justice in the Workplace 

August 22, 2022 

Buffalo, NY 

Witnesses 

• Thomas Beauford, Jr., President and CEO, Buffalo Urban League 

• Mark Blue, President, NAACP-Buffalo 

• Trina Burruss, Chief Operating Officer, United Way of Buffalo and Erie County 

• Zeneta Everhart, Community Advocate & Mother of Tops Shooting Victim 

• Kimberly Hayward, Hospital Worker & Lead Plaintiff in Race Discrimination Suit 

• Kelly Hernandez, Member of the Board of Directors, Hispanic Heritage Council of Western 

New York 

• Maureen Kielt, Director, EEOC Buffalo Local Office 

• Cindi McEachon, CEO, Peaceprints of Western New York (WNY) 

• Brendan R. Mehaffy, Executive Director, City of Buffalo Office of Strategic Planning 

• Clotilde Perez-Bode Dedecker, President and CEO, Community Foundation for Greater Buffalo 

• John Somers, President and CEO, Harmac Medical Products, Inc. 

• Henry Louis Taylor, Jr., Director, Center for Urban Studies, University at Buffalo 

• Rolanda Ward, Associate Professor and Endowed Faculty Director of the Rose Bente Lee 

Ostapenko Center for Race, Equity, and Mission, Niagara University 

• Garnell Whitfield, Jr. , Community Advocate & Son of Tops Shooting Victim 
U.S. Equal Employment Opportunity Commission 22 Strategic Enforcement Plan 2024–2028

SEP Listening Session 2 

Identifying Vulnerable Workers and Reaching Underserved Communities

September 12, 2022 

Virtual 

Witnesses 

• Ian Anderson, Legal Services Project Manager, Transgender Law Center 

• Vidhi Bamzai, Staff Attorney, Southern Poverty law Center (SPLC) 

• Marisa Diaz, Senior Staff Attorney, Legal Aid at Work 

• Monica Guizar, Lead Counsel, Property Services Division of Service Employees International 

Union (SEIU) 

• Julie Kegley, Senior Staff Attorney and Program Director, Georgia Advocacy Office 

• Maria Lopez, Staff Attorney, Indigenous Program at California Rural Legal Assistance, Inc. 

• Marisa Lundin, Legal Director, Indigenous Program at California Rural Legal Assistance, Inc. 

• Chanchanit (Chancee) Martorell, Founder & Executive Director, Thai Community Development 

Center (Thai CDC) 

• Blanca Rodriguez, Deputy Director of Advocacy, Columbia Legal Services 
U.S. Equal Employment Opportunity Commission 23 Strategic Enforcement Plan 2024–2028

SEP Listening Session 3 

Shaping the EEOC’s Strategic Enforcement Priorities 

September 22, 2022 

Washington, DC 

• Holly Biglow, Government Affairs Director, AARP 

• Judi Conti, Director of Government Affairs, National Employment Law Project 

• Linda Correia, President, National Employment Lawyers Association (NELA) 

• Emily Dickens, Chief of Staff and Head of Government Affairs, Society for Human Resource 

Management (SHRM) 

• David Fortney, Co-Founder, Fortney & Scott 

• Darrell Gay, Partner, ArentFox Schiff 

• Eve Hill, Partner, Brown Goldstein & Levy 

• Manjusha Kulkarni, Executive Director, AAPI Equity Alliance 

• Emily Martin, Vice President for Education and Workplace, National Women’s Law Center 

• Nick Reaves, Counsel, Becket 

• Dariely Rodriguez, Deputy Chief Counsel, Lawyers Committee for Civil Rights Under Law 

• Chris Williams, Director of Litigation, National Legal Advocacy Network 
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