EEOC to Rescind Enforcement Guidance on Criminal Background Checks. The U.S. Equal Employment Opportunity Commission (EEOC) plans to rescind its “Enforcement Guidance on the Consideration of Arrest and Conviction Records in Employment Decisions under Title VII of the Civil Rights Act,” which it most recently updated in 2012. The Commission has sent the Office of Information and Regulatory Affairs (OIRA) a draft rescission of the guidance, characterized as a “final rule,” which likely means there will be no opportunity for public comment. The guidance states that an employer’s neutral criminal background check policy could have a disparate impact on protected applicants, and it strongly suggests that employers using background screens deploy a nine-factor “individualized assessment” to avoid potential liability under Title VII of the Civil Rights Act of 1964. The EEOC’s decision to rescind the guidance is consistent with the Commission’s and the administration’s deemphasis of the disparate impact theory of discrimination.

The guidance is an example of how policy debates evolve over time. In 2012, the background check guidance caused quite a stir within the business community, which expressed concern that the update potentially limited employers’ ability to protect employees and customers. Over the years, however, perspectives on the issue evolved, and the Commission came to reconsider its approach. Stephen R. Woods, Gustavo A. Suárez, Amie M. Willis, and Leah J. Shepherd have the details.

USCIS Would Prefer Not to Defer. This week, U.S. Citizenship and Immigration Services (USCIS) issued a proposed rule, titled, “Removing Deference to Prior USCIS Determinations of Eligibility.” The proposal would rescind the current regulation that requires USCIS, when processing an extension-of-stay request, to give “deference to a prior determination of the petitioner’s, applicant’s, or beneficiary’s eligibility.” USCIS argues that “the deference regulation and policy risk undermining program integrity by potentially reducing scrutiny of extension requests of nonimmigrant worker classifications, thereby potentially perpetuating erroneous prior approvals and creating an environment in which fraudulent and meritless petitions are less likely to be detected before approval.”

The proposal, which did not appear in the administration’s Unified Agenda of Federal Regulatory and Deregulatory Actions (“Regulatory Agenda”) released on July 3, 2026, is the latest iteration of a policy that has changed multiple times over recent administrations. Public comments on the proposal are due by November 13, 2026.

USCIS Finalizes Elimination of 540-Day Automatic Work Authorization Extension. On October 14, 2026, USCIS issued a final rule that officially ends the automatic extension of immigrants’ work authorizations while their work authorization renewals are pending. The change in policy had already been promulgated via an interim final rule (IFR) issued on October 30, 2025, and this week’s action adopts the rule—without changes to the IFR—permanently.

USCIS to Change Premium Processing? USCIS has sent OIRA a draft proposal, titled, “Amending the Premium Processing Timeframe.” Because the proposal did not appear in the Regulatory Agenda, no information about its contents has been made public. The Buzz expects this initial review period to last several weeks, after which USCIS will likely publicly release the proposal, potentially laying the groundwork for a lengthening of the applicable premium processing periods. The premium processing timeframes are currently fifteen, thirty, or forty-five business days.

The House Votes to Remain in D.C. On October 15, 1814, the U.S. House of Representatives voted to keep the nation’s capital in Washington, D.C. Just weeks earlier, in the midst of the War of 1812, the British Army set fire to many of the city’s public buildings, including the U.S. Treasury, the Capitol, and the White House. When Congress returned to Washington, D.C., in September 1814, it met temporarily in one of the few remaining public buildings—the U.S. Patent Office. The major topic of debate in the weeks that followed was whether to permanently move the capital to a more secure location. As with previous negotiations over the capital’s location, this debate generally divided along northern and southern lines, with legislators from northern states advocating for a move to Philadelphia or New York, and southerners arguing for remaining in the District of Columbia. Finally, on October 15, 1814, a resolution to move the capital to Philadelphia failed in the House by a vote of 74–83. Thereafter, Congress met at various locations throughout the city—including the Old Brick Capitol on the site of the current Supreme Court Building—until the Capitol was repaired.

Quick Hits

• Governor Matt Meyer signed amendments to the Delaware Personal Data Privacy Act on September 2, 2026, that further limit profiling and automated decision-making based on the personal data of job applicants, employees, and independent contractors.
• Violations of the law can result in civil penalties up to $10,000 per violation.
• The amendments will take effect on January 1, 2027.

The Delaware Personal Data Privacy Act (DPDPA) took effect on January 1, 2025. The law currently regulates people who conduct business in Delaware (or people producing products or services targeted to Delaware residents) that process personal data of at least 35,000 Delaware consumers, or process personal data of at least 10,000 Delaware consumers and derive at least 20 percent of their annual revenue by selling personal data. Beginning on January 1, 2027, those numbers will drop to 10,000 for the first category and 5,000 for the second category.

Similar to other comprehensive privacy laws across the country, personal data under the DPDPA includes any information that is “linked or reasonably linkable to an identified or identifiable individual,” but does not include deidentified data or publicly available information, and relies on the twin concepts of “controllers” and “processors.” It also requires a privacy notice.

The DPDPA does not currently apply to data collected by employers for hiring and employment purposes (although that will change somewhat starting on January 1, 2027), medical data covered by the Health Insurance Portability and Accountability Act (HIPAA), and clinical trial data, as well as a number of other exclusions for certain types of entities (e.g., those engaged in insurance, banking, and securities). Violations of DPDPA may result in civil penalties up to $10,000 per violation.

The DPDPA permits Delaware consumers to access, correct, and delete their personal data and opt out of targeted advertising, data sales, and certain profiling. The law requires a consumer’s consent before processing sensitive data, including a person’s race, national or ethnic origin, religion, sexual orientation, immigration status, genetic and biometric data, financial credentials, and precise geolocation data.

The amendments expand the definition of sensitive data to encompass mental or physical health treatment or diagnosis, neural data, and certain financial data that would allow access to a consumer’s financial account, as well as inferences made based on personal data that would reveal the same. The amendment prohibits the sale of sensitive data unless:

• the disclosure of sensitive data is “strictly necessary” to provide or maintain a product or service affirmatively requested by the consumer;
• the controller provides a “clear and conspicuous” notice of the sale of personal data before the sale;
• the controller maintains a record of the consumer’s consent for five years; and
• the record of consent is provided with any data protection assessment requested by the Delaware attorney general.

The amendments introduce a requirement for controllers to conduct impact assessments if they process the personal data of 50,000 or more Delaware consumers for processing activities that may present a “heightened risk of harm” to a consumer, which includes targeted advertising, the sale of personal data, the profiling of a consumer (where it presents a risk of unlawful discrimination, financial injury, or intrusion into privacy affairs), or the processing of sensitive data. The same applies where a processor may be profiling consumers in furtherance of automated decisions that produce legal or similarly significant effects on a consumer. Profiling includes any form of automated processing performed on personal data to evaluate, analyze, or predict factors related to demographic characteristics, personal preferences, interests, reliability, behavior, location, or movements.

Legal or similarly significant decisions are those that would result in the provision or denial of employment opportunities, insurance, healthcare services, financial services, housing, education enrollment, criminal justice, or access to essential goods or services.

An impact assessment must include the intended uses of the profiling, reasonably foreseeable risks of harm, categories of personal data processed, performance metrics and known limitations, transparency measures, and post-deployment monitoring and safeguards.

Hiring and Employment Decisions

One important aspect of the new amendments is that, while the law continues to exclude employees from the definition of “consumers,” the amendments introduce a separate category known as “residents,” who do not share all of the same rights as consumers, but which may provide a new, separate basis for regulating employers indirectly via their status as a third party that acquires personal data from a controller.

While employment-related personal data is still generally excluded, now subject to the DPDPA will be personal data processed in connection with profiling and reports, meaning written, oral, or other communication of personal data by a controller or processor, including recommendations, summaries, and automated decisions based on personal data or profiling.

The DPDPA may come into play where an employer orders a report from a vendor (acting as a controller), and such report is not a consumer report or would not be if disclosed to a third party, it is not furnished or disclosed in compliance with the Fair Credit Reporting Act (FCRA), and it is used or relied upon in connection with a decision resulting in the provision or denial of employment opportunities for a Delaware resident.

It seems that Delaware was seeking to address that gray area where employers have asked vendors (often incorporating automated decision-making tools) to source, screen, or rank job candidates, partly based on outside data assembled by the vendor, and ultimately used the information to make a decision on a candidate before ever reaching the official background check stage regulated by the FCRA.

Under the amendments, the controller is responsible for imposing contractual obligations on third parties receiving the report, including notifying the resident of any adverse action based on the report, a description of the personal data relied upon in making the adverse action, the resident’s right to obtain information from the controller, and the resident’s right to have the controller perform a human review of the adverse action. In addition, the controller must, upon request from the resident, provide within thirty days the personal data maintained about the resident, the source of the personal data used in profiling, identify all third parties that obtained a report concerning the resident within the previous twenty-four months, and the opportunity to correct any incorrect personal data.

Controllers also may not process personal data or engage in profiling in violation of state or federal laws prohibiting unlawful discrimination. Delaware considers anti-bias testing for AI tools (or lack thereof) to be relevant to any claims for such violations.

Next Steps

Delaware’s privacy law amendments arrived as an increasing number of states are adopting and refining their comprehensive data privacy laws. Delaware employers may still process the personal data of job applicants and employees, but may want to review how they use AI tools in recruiting, hiring, performance reviews, discipline, and termination decisions, and take adequate steps to ensure compliance with the new amendments to the privacy law before January 1, 2027.

Ogletree Deakins’ Artificial Intelligence and Innovation Practice Group and Cybersecurity and Privacy Practice Group will continue to monitor developments and will post updates on the Artificial Intelligence and Innovation, Cybersecurity and Privacy, and Delaware blogs as additional information becomes available.

Harris S. Freier is a shareholder in Ogletree Deakins’ Morristown office.

Elizabeth R. Lash is senior counsel in Ogletree Deakins’ New York City office.

This article was co-authored by Leah J. Shepherd, who is a writer in Ogletree Deakins’ Washington, D.C., office.

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Quick Hits

• A Massachusetts federal judge enforced Fresenius’s noncompete agreement against a former supply chain executive who accepted employment with Vantive, a direct competitor, finding that the agreement adequately identified his employer and was properly executed.
• The court held that the restrictions were no broader than necessary under the Massachusetts Noncompetition Agreement Act because the executive had access to confidential companywide information and competitive strategies, and the restrictions applied only to duties substantially similar to those he performed for Fresenius.
• Finding that Fresenius was likely to succeed on its breach of contract claim and faced irreparable harm from the executive’s potential use of confidential information, the court barred him from working for Vantive until July 2027.

In Fresenius USA Manufacturing, Inc. v. Micah Much, the company sought to enforce certain noncompetition provisions in its “Employee Confidentiality, Assignment and Protective Covenants Agreements” that it entered into with the defendant during his employment (and in exchange for which the defendant was given significant compensation). The agreements specifically prohibited the defendant from “working for or in furtherance of any ‘Competing Business’ within the ‘Restricted Area’ under circumstances where his ‘duties, services, and/or responsibilities are the same as or substantially similar to any of the duties and responsibilities’ performed for Fresenius” in the twelve months immediately following the termination of his employment with Fresenius.

The defendant worked for Fresenius from September of 2022 to July of 2026 as its vice president of Supply Chain Americas. In connection with his position at Fresenius, the defendant was responsible for overseeing supply chain management, among other things, for one of Fresenius’s divisions. He was involved in discussions regarding confidential information with other executives, as well as confidential strategic initiatives in furtherance of Fresenius’s business. Then, in May of 2026, the defendant interviewed with Vantive, a company that Fresenius described as its direct competitor. He began working as Vantive’s executive vice president and chief supply chain officer in late July 2026 and was responsible for overseeing Vantive’s global logistics and supply chain operations. Importantly, Fresenius also alleged in its filings that the defendant attended a meeting in which the business discussed potential strategies for competing with Vantive.

In early August 2026, Fresenius filed a petition for a preliminary injunction, arguing that the defendant breached the agreements by providing services to Vantive in connection with his new position. In his objection, the defendant argued the noncompetition provisions were unenforceable, since the name of his specific employer, Fresenius USA Manufacturing, was not stated in the agreements. Instead, he argued, only “Fresenius Medical Care Holdings, Inc.” appeared in the agreements. The defendant further argued that his employer did not sign the agreements.

The court rejected the defendant’s arguments and held the agreements were enforceable under the MNAA. First, the court explained that the agreements defined “the Employer” as “a subsidiary of Fresenius Medical Care Holdings, Inc.” Since the defendant was only employed by one subsidiary, this definition sufficiently identified the defendant’s “specific employer rather than the broader … parent company.” The court also held that the agreements were signed by individuals “[o]n behalf of the Employer,” who had the requisite authority to sign on behalf of Fresenius.

To be enforceable, the MNAA also requires noncompete provisions to be “no broader than necessary to protect … legitimate business interests of the employer.” In rejecting the defendant’s argument that the agreements were overly broad since they referenced the entire company’s confidential information and competitors instead of limiting it to the subsidiary that employed the defendant, the Fresenius court held that the agreements were not any broader than necessary. In so holding, the court reasoned that, because the defendant had knowledge of confidential information and trade secrets across the business, including strategies for competing with the defendant’s new employer, the restrictions were not broader than necessary. Moreover, the court noted that the restrictions were limited to the duties and responsibilities that the defendant actually performed.

The court next evaluated whether Fresenius demonstrated a likelihood of success on the merits with respect to its breach of contract claim. The defendant argued it had not, asserting his job duties at Vantive were “materially different” than the ones he fulfilled at Fresenius since he would only have “some responsibility for logistics functions,” with the majority of his focus being on “driving continuity, strategy, and excellence across Vantive’s supply chain functions.” In the court’s view, Fresenius demonstrated a likelihood of success, finding the defendant’s work for Vantive to be “substantially similar to at least some of the duties and responsibilities he had with Fresenius in the past two years.” Fresenius also demonstrated that it would suffer irreparable harm without an injunction, since the defendant had access to “several executive meetings discussing … plans for improving its supply chain … and at least one meeting discussing Fresenius’s strategies about competing with Vantive.” According to the court, it was logical to conclude that the defendant would “use his knowledge of [Fresenius]’s supply chain and strategies to the benefit of his former employer’s direct competitor.” The court ordered the defendant to cease his work at Vantive until July 2027.

Ogletree Deakins’ Boston office will continue to monitor developments and will post updates on the Healthcare, Massachusetts, and Unfair Competition and Trade Secrets blogs as additional information becomes available.

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Quick Hits

• On October 6, 2026, Washington DOSH proposed updates to construction PPE rules to align with federal OSHA requirements, including requiring employers to ensure PPE properly fits each affected employee.
• The proposal also includes minor clarifications and housekeeping revisions, with public hearings in November 2026, comments due November 23, 2026, and intended adoption on March 2, 2027.

DOSH’s primary purpose for this proposed rulemaking is to bring Washington’s construction PPE requirements in line with the federal construction PPE requirements, which were updated by the federal Occupational Safety and Health Administration (OSHA) and took effect January 2025.

The most significant proposed change to Washington’s existing construction PPE rule would require employers to “ensure that [the PPE] properly fits each affected employee.” Washington’s existing construction PPE rule does not include a requirement that the employer ensure that the PPE fits the affected employees. As the proposed rulemaking describes, federal OSHA similarly revised the federal construction PPE requirement in January 2025 to require employers to ensure that PPE properly fits each affected employee.

Notably, the proposed rule does not provide any definition or guidelines for what it means for PPE to “properly” fit an employee. Similarly, the federal OSHA rule upon which the proposed rulemaking is based also does not define the term “properly fits.”

There are also some smaller proposed changes to the rule, including revising the language of the rule so that it states expressly that employers are responsible for providing certain PPE. Other small “housekeeping” changes are also proposed, including formatting changes and the correction of typographical errors.

DOSH will hold two public virtual and telephonic hearings on the proposed rulemaking on November 10, 2026, and November 16, 2026, and the public is invited to submit comments on the proposed rulemaking until November 23, 2026. DOSH’s date of intended adoption for the revised rule is March 2, 2027.

Ogletree Deakins’ Seattle office and Workplace Safety and Health Practice Group will continue to monitor developments and provide updates on the Construction, Washington, and Workplace Safety and Health blogs as additional information becomes available.

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Probably not. The clause’s flow-down requirement contains an exception for subcontracts where the place of “delivery or performance” is outside the United States.

Because the exception is written in the disjunctive (i.e., “expressed by mutually exclusive alternatives joined by or”), a subcontract performed outside the United States may qualify for the exception even when the finished goods are delivered in the United States. That relatively straightforward example, however, raises harder questions for global supply chains in which manufacturing, assembly, installation, services, and delivery occur in multiple countries.

Quick Hits

• FAR 52.222-90, “Addressing DEI Discrimination by Federal Contractors,” flows down to subcontracts at any tier, including subcontracts for commercial products and commercial services, subject to an exception where the place of “delivery or performance” is outside the United States.
• The use of “or” is significant. A foreign manufacturer that performs a supply subcontract entirely at an overseas facility may fall within the exception even if the finished goods are shipped FOB destination to a U.S. location.
• The more difficult questions arise when subcontract performance occurs partly inside and partly outside the United States. FAR 52.222-90 does not expressly address how the geographic exception applies to mixed-location performance.

Applying any FAR flow-down clause begins with identifying which lower-tier relationships are subcontracts. As we discussed in a prior article on the DEI clause, the FAR defines “subcontractor” broadly to include “any supplier, distributor, vendor, or firm that furnishes supplies or services to or for a prime contractor or another subcontractor” (FAR 44.001), although the line between a subcontractor and a vendor is not always bright. FAR 52.222-90 adds a second threshold question: even when a supplier is a subcontractor, does the geographic exception to the flow-down requirement apply?

That question is particularly important for commercial companies with global supply chains. A product may be manufactured overseas, transported to the United States, installed by personnel in another country, or pass through multiple affiliates before reaching the government. The text of FAR 52.222-90 suggests that contractors should examine both where delivery occurs and where the subcontract is performed before deciding whether the clause must be flowed down.

The Clause and Its Flow-Down Provision

FAR 52.222-90 implements EO 14398 and appears in the Revolutionary FAR Overhaul (RFO) version of FAR Part 52 posted on Acquisition.gov, which the FAR Council intends to finalize through notice-and-comment rulemaking. Contracting officers insert the clause in solicitations and contracts valued over the micro-purchase threshold, including those for commercial products and commercial services, subject to the clause’s geographic limitation. The clause is also listed among the clauses that flow down to commercial subcontracts under FAR 52.244-6.

Paragraph (c) of FAR 52.222-90 requires contractors to include the substance of the clause in subcontracts at any tier, including those for commercial products and commercial services, “except those where the place of delivery or performance is outside the United States.” The wording of the exception matters. The clause does not require both delivery and performance to occur outside the United States. Instead, it uses the disjunctive “or.” Under the ordinary reading of that language, a subcontract should fall within the exception if either its place of delivery or its place of performance is outside the United States.

The resulting compliance determination can be important. As we discussed in a prior article, FAR 52.222-90 requires prime contractors to report certain “known or reasonably knowable” subcontractor conduct that may violate the clause, states that compliance is material to the government’s payment decisions for purposes of the False Claims Act, and is paired with new causes for suspension and debarment. Contractors, therefore, have reason to determine carefully which subcontracts actually fall within the clause’s flow-down requirement.

Place of Performance and Foreign-Manufactured Goods

For a straightforward supply subcontract, identifying the place of performance may be relatively simple. The FAR treats “deliveries or performance” as a schedule term specifying the time, place, and method of delivery or performance (FAR 15.209-1), and its “place of performance” provisions (FAR 52.215-6 and 52.214-14) ask offerors to identify the street address of any plant or facility used in performing the contract.

For a supply contract, performance generally occurs where the goods are manufactured, assembled, or otherwise produced. A foreign manufacturer that makes a commercial product entirely at its own plant overseas therefore has a strong basis for concluding that the subcontract is performed outside the United States.

The fact that the finished product is ultimately delivered to the United States should not, standing alone, change that conclusion. Consider a German manufacturer that produces a commercial product entirely at its German facility and ships the product FOB destination to its customer’s warehouse in Virginia. Under FAR transportation terminology, the contractual place of delivery may be Virginia. But the place of performance remains Germany. Because FAR 52.222-90 excepts subcontracts where the place of “delivery or performance” is outside the United States, the foreign place of performance should be sufficient to bring the subcontract within the exception.

This reading is also significant because other FAR clauses use different language when the drafters intend any U.S. performance to trigger a requirement. For example, FAR 52.222-55 addresses subcontracts “performed in whole or in part in the United States,” while FAR 52.203-14 uses the formulation “performed entirely outside the United States.” FAR 52.222-90 uses neither formulation. Instead, it asks whether the “place of delivery or performance is outside the United States.”

Those textual differences become important when a subcontract does not have a single, easily identifiable place of performance.

FOB Terms Still Matter, but They Do Not End the Analysis

Although an overseas place of performance may independently satisfy the exception, delivery remains relevant because FAR 52.222-90 expressly identifies it as a separate geographic consideration.

The FAR does not define “place of delivery” specifically for purposes of FAR 52.222-90, but it does define how delivery terms work. FAR 2.101 defines “FOB” (or “F.o.b.”) as a term used in conjunction with a physical point to determine responsibility and the basis for payment of freight charges and, unless otherwise agreed, the point where title for goods passes to the buyer or consignee.

Under “F.o.b. origin,” the seller or consignor places the goods on the conveyance, and the buyer or consignee generally assumes responsibility for transportation and risk of loss. Under “F.o.b. destination,” the seller or consignor delivers the goods at the specified destination and generally remains responsible for transportation and risk of loss until the goods reach that point.

FAR Subpart 47.3 also recognizes delivery terms tailored to international shipments, including “F.o.b. vessel, port of shipment” and “F.o.b. inland point, country of importation.” The FAR expressly contemplates that supplies originating outside the contiguous United States may be acquired on either an “F.o.b. origin” or “F.o.b. destination” basis (FAR 47.304-4).

Those rules can help identify the place of delivery, but they should not be used to collapse the two parts of the FAR 52.222-90 exception into a single delivery test. If a foreign manufacturer produces goods entirely overseas and ships them “F.o.b. destination” to the United States, the U.S. delivery point does not eliminate the fact that performance occurred outside the United States. Conversely, a U.S. manufacturer that produces goods domestically but contractually delivers them at an overseas destination may have an argument that the foreign place of delivery itself satisfies the exception.

The result is that contractors likely will want to analyze delivery and performance independently rather than stopping the analysis after identifying a U.S. nexus.

The Harder Question: Performance in More Than One Country

The more difficult cases arise when a subcontract involves performance both inside and outside the United States.

Consider a foreign manufacturer that builds specialized equipment at its facility in France and ships the equipment to a U.S. contractor. The manufacturer then sends technicians to the United States to install, test, and commission the equipment. The subcontract plainly involves substantial performance outside the United States, but it also involves performance in the United States.

FAR 52.222-90 does not expressly state how its exception applies to that situation. It does not say that the exception is limited to subcontracts “performed entirely outside the United States.” Nor does it state that the clause applies whenever a subcontract is performed “in whole or in part” in the United States. The absence of either formulation leaves room for questions about how to identify “the place of performance” when there is more than one place.

Similar issues can arise when a product is manufactured overseas but customized or assembled in the United States, when testing occurs at facilities in multiple countries, or when a foreign supplier provides both products and services under the same subcontract. A contractor’s foreign affiliate may purchase goods abroad and transfer them to a U.S. entity, and FAR 52.244-6 provides that “subcontract” includes certain transfers of commercial products between divisions, subsidiaries, or affiliates at any tier. In each case, identifying a single “place of performance” may be considerably more difficult than it is for a finished commercial product manufactured entirely at one overseas facility.

Implications for Flow-Down Compliance

For companies subject to FAR 52.222-90, the geographic exception is ultimately a supply-chain and flow-down compliance issue. But the exception may be broader than contractors initially assume.

A U.S. destination does not necessarily mean that a foreign supplier must receive the clause. When a commercial product is manufactured entirely outside the United States, the overseas place of performance provides a substantial basis for applying the exception even if the supplier delivers the finished product to a U.S. location. Likewise, a foreign place of delivery may independently be relevant even where some performance occurs domestically.

The harder cases are those in which the subcontract itself crosses geographic boundaries. Contractors evaluating those relationships may want to identify where the material elements of the subcontract occur, including manufacturing, assembly, customization, testing, installation, services, and contractual delivery. They also may want to document the basis for determining whether the geographic exception applies, particularly where performance occurs in multiple countries.

For foreign commercial companies supplying goods into the U.S. federal market, the practical takeaway is equally important. The mere fact that a product ultimately reaches the United States does not necessarily subject the foreign manufacturer to FAR 52.222-90. The analysis should focus on the actual places of delivery and performance under the subcontract. Contractors may want to pay close attention to the clause’s particular wording. The word “or” may do significant work in determining the reach of FAR 52.222-90, while mixed-location performance may present the more difficult compliance question.

Next Steps

Ogletree Deakins’ Diversity, Equity, and Inclusion Compliance Practice Group, Government Contracting and Reporting Practice Group, and Workforce Analytics and Compliance Practice Group will continue to monitor developments and provide updates on the Diversity, Equity, and Inclusion Compliance, Government Contracting and Reporting, 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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Quick Hits

• AI-enabled smart glasses create workplace compliance risks by enabling discreet recording, data capture, transcription, and AI analysis in settings where traditional smartphone policies may not apply.
• Employers may want to update recording and confidentiality rules to address wearable devices while accounting for consent laws, biometric privacy, trade secrets, investigations, and third-party data handling.
• Employers may want to ensure that restrictions are narrowly tailored to comply with labor laws and to preserve processes for disability accommodations, meeting protocols, and consistent manager enforcement.

The Smartphone Isn’t the Only Compliance Problem

AI-enabled glasses look like ordinary eyewear. But depending on the model, they can take photos, record video and audio, livestream, transcribe conversations, translate speech, and send what they capture to an AI assistant for analysis—all hands-free, and often with little more than a small indicator light to signal that anything is happening.

As these devices move from novelty to mainstream, employers are fielding new questions: Can an employee wear them on the floor? In a meeting? In an investigation interview? What about a candidate who shows up to an interview wearing them? The short answer is that existing policies may not have an answer at all. Below are seven issues employers may want to address now.

Issue #1: Workplace Recording and Consent Laws

Recording laws (also known as wiretapping laws) vary by state. Federal law and most states follow a one-party consent rule: a conversation may be recorded if one participant consents—including the person doing the recording. A minority of states, including California, Florida, Illinois, Maryland, Massachusetts, Montana, New Hampshire, Pennsylvania, and Washington, generally require the consent of all parties, at least where participants have a reasonable expectation of privacy.

Smart glasses make inadvertent violations easy. An employee in a one-party consent state who joins a video call with colleagues in an all-party consent state may trigger the stricter rule without realizing it. For multistate employers, a single, uniform recording rule may not map neatly onto every location—or every meeting.

Traditional recording policies compound the problem. Many were drafted with phones and handheld recorders in mind and refer to “cameras” or “recording devices” in ways that may not obviously reach a pair of glasses. If the policy does not clearly (either specifically or broadly) cover the device, enforcement becomes an argument rather than an expectation.

Issue #2: Trade Secrets and Confidential Information

Trade secret protection depends, in part, on an employer’s reasonable efforts to keep information secret. A device that can passively capture everything in a wearer’s line of sight tests those efforts. Risk areas include:

• Manufacturing environments, where proprietary processes, equipment configurations, and formulas are visible on the floor.
• Customer information, including data displayed on screens or discussed on calls.
• HR investigations, where witness identities and allegations are highly sensitive.
• Internal business discussions, such as strategy sessions, pricing, and deal planning.
• Attorney-client communications, where a recording—particularly one routed to a third-party AI platform—could raise questions about confidentiality and potential waiver of privilege.

Uploading captured material to a cloud-based service adds another layer: once information leaves the employer’s systems, control over it may be lost.

Issue #3: Privacy and Biometric Data

Smart glasses do not just capture images; they can capture faces and voices. If captured data is processed using facial recognition or voiceprint technology, biometric privacy statutes may come into play. Illinois’s Biometric Information Privacy Act (BIPA), with its private right of action, is the most prominent example, while Texas, Washington, and a growing number of comprehensive state privacy laws also regulate biometric data.

The privacy implications extend beyond employees. Customers, patients, visitors, and vendors may be recorded without knowing it—raising concerns in health care, retail, financial services, and any setting where third-party privacy is expected. And when captured information is fed into outside tools, employers may have limited visibility into how that data is stored, analyzed, or used.

Issue #4: The NLRA Complicates Blanket Prohibitions

The instinctive response—ban the glasses—carries its own risk. Section 7 of the National Labor Relations Act (NLRA) protects employees’ right to engage in protected, concerted activity for mutual aid or protection, whether or not they are unionized. The National Labor Relations Board (NLRB) has long recognized that recording can, in some circumstances, be part of protected activity, such as documenting unsafe conditions or capturing evidence of disparate treatment.

Under the Board’s 2023 decision in Stericycle, Inc., a work rule that could reasonably be interpreted to chill Section 7 activity is presumptively unlawful unless the employer shows the rule advances a legitimate and substantial business interest that cannot be achieved with a more narrowly tailored rule. The Board’s composition and priorities shift politically, and Stericycle may be revisited, but employers may want to draft with the current standard in mind.

The practical lesson: employers may want to tie restrictions to specific, articulated interests—confidentiality, safety, privacy, privilege—and to specific locations or activities, rather than prohibiting all recording everywhere.

Issue #5: ADA Accommodation Considerations

Smart glasses are not just consumer gadgets; for some employees, they may function as assistive technology. Real-time transcription and captioning may help employees who have hearing-related conditions. Object recognition, text reading, and scene description may assist employees with vision-related conditions. Prompts and reminders may support employees with certain cognitive or neurological conditions.

A request to use smart glasses as an accommodation should trigger the interactive process under the Americans with Disabilities Act (ADA) and analogous state laws. A blanket ban does not relieve an employer of that obligation. Employers may consider whether the device can be used with recording or AI features limited, in designated areas, or with other safeguards—or whether an alternative accommodation would be effective.

Issue #6: Interviews, Investigations, and HR Meetings

Some of the most sensitive moments in the employment relationship happen in a conference room. Smart glasses raises distinct questions in each:

• Candidate interviews. A candidate may use smart glasses to record the interview—or to receive real-time coaching or answers—raising both consent and assessment-integrity concerns.
• Workplace investigations. Undisclosed recordings can compromise witness confidentiality, chill candor, and complicate the investigative record.
• Discipline and termination meetings. A recording made without the employer’s knowledge may surface later as evidence in litigation or an agency charge.

Practical protocols may include asking at the start of every interview or meeting whether any device is recording, documenting the response, reminding participants of applicable policies, and offering an alternative—such as a written summary—where appropriate. HR professionals may also want to be trained to recognize the devices, since they may look like ordinary prescription glasses.

Issue #7: Policy Drafting Considerations

For most employers, the fix is not a new policy but an updated one. Suggested action items may include:

• Reviewing recording-device policies. This includes identifying gaps created by wearable technology.
• Defining covered devices broadly.
• Focusing on function—capturing audio, images, or video, or transmitting data—rather than form.
• Expressly including wearables and AI devices.
• Naming smart glasses and similar technology to remove ambiguity.
• Addressing confidentiality and safety rationales.
• Articulating the business interests behind each restriction and where it applies.
• Preserving NLRA rights. This would include clear savings language and avoiding overbroad prohibitions.
• Leaving room for ADA accommodations.
• Providing a path for employees to request exceptions through the interactive process.
• Training managers on enforcement.
• Helping supervisors recognize the devices and applying the policy consistently and lawfully.

Practical Takeaway

The question is no longer whether employees will bring AI-enabled eyewear into the workplace. The question is whether employers’ policies were written for a smartphone era and are prepared for a wearable-AI era.

Many employers already have recording policies. Few were designed for glasses that can passively record, transcribe, and analyze the workplace. Because this technology sits at the intersection of privacy, labor relations, accommodations, investigations, trade secrets, and AI governance, a measured, cross-functional review now may prevent a far more complicated conversation later.

Ogletree Deakins’ Artificial Intelligence and Innovation Practice Group and Cybersecurity and Privacy Practice Group will continue to monitor developments and will post updates on the Artificial Intelligence and Innovation, Cybersecurity and Privacy, and Employment Law blogs as additional information becomes available.

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SCOTUS Begins 2026–2027 Term. This week, the Supreme Court of the United States kicked off its 2026–2027 term. The Court will continue to fill its docket in the coming weeks, but it already has several cases that should be of interest to employers (though these cases are perhaps a bit more esoteric than those of the last term, which dealt with matters concerning presidential removal powers and birthright citizenship, among others).

For example, the justices will review a case concerning pleading standards when challenging imprudent investments under the Employee Retirement Income Security Act of 1974. Another case to be heard by the Court addresses whether the United States Constitution prohibits the U.S. Department of Labor’s (DOL) administrative law judges from imposing monetary penalties on employers for H-2A violations following the Court’s 2024 decision involving the U.S. Securities and Exchange Commission.

The justices will also examine whether employees of federally funded educational institutions can pursue employment discrimination claims under Title IX of the Education Amendments of 1972—which allows for quicker access to courts and does not have statutory caps on damages—as opposed to Title VII of the Civil Rights Act of 1964. Finally, the Court will decide whether an employer can raise an affirmative defense for the first time at summary judgment that it has not previously raised without amending its answer.

DHS Proposes OPT Fee Rule. On October 10, 2026, the U.S. Department of Homeland Security (DHS) issued a notice of proposed rulemaking (NPRM or “proposal”) on “Optional Practical Training Fees.” Key elements of the proposal are as follows:

• Initial fee. The NPRM proposes that schools be charged a fee of $70,000 per F-1 nonimmigrant student the first time that they recommend an F-1 nonimmigrant student for any type of optional practical training (OPT).
• Additional fee. The NPRM also proposes a requirement that these schools then pay a $30,000 fee for each additional time they recommend the student for OPT. For example, a school would be required to pay a total of $100,000 for a student who engages in OPT prior to completing his or her program ($70,000), followed by post-graduation OPT ($30,000).
• Who pays? Schools would be required to pay the fee, but “DHS acknowledges that the schools may pass the financial obligation of this proposed fee onto F-1 nonimmigrant students, all students, or employers.”
• Effective date. The rule would apply prospectively to F-1 nonimmigrant students who apply for OPT after the effective date of the final rule, which would be sixty days after its publication in the Federal Register.
• Foreshadowing? DHS warns stakeholders that “absent these fees, it will not be able to operate OPT consistent with its focus on preventing fraud and protecting American workers and may shut down the program entirely.” (Emphasis added.)

DHS maintains that the proposal is necessary “to ensure that schools, students, and employers participate in OPT for its intended purpose instead of [as] a means to circumvent the H-1B visa program.” Because the fee is designed to have a deterrent effect, it will be deposited in the U.S. Treasury and not earmarked for any DHS processing or operational costs. Comments must be received on or before November 9, 2026.

Andrew G. Drozdowski, Amanda R. Goodman, and Tiffany Lam-Bentley have additional details.

Unions, Immigration Groups File Challenge to Policies on Adjustment of Status and Benefits Denials. A coalition of labor unions and immigrants’ rights groups has filed a legal challenge in the U.S. District Court for the District of Massachusetts against two recent DHS policies regarding adjustment of status applications and denials of benefit requests. The lawsuit alleges that these policies exceed DHS’s statutory authority and violate the Administrative Procedure Act because they are arbitrary and capricious (as DHS arguably failed to articulate a reasoned explanation for the policy changes and did not consider reliance interests) and because the policies were issued without providing the public notice or an opportunity to comment on the changes. The complaint also alleges that the policies violate the due process clause of the Fifth Amendment because they fail to provide an adequate or fair procedure for adjudicating adjustment-of-status applications. The lawsuit asks the court to preliminarily enjoin the policies during the challenge and vacate them.

FLSA Independent Contractor Reg. Moves Forward. The DOL’s Wage and Hour Division (WHD) sent the Office of Information and Regulatory Affairs (OIRA) a final version of its rule relating to independent contractor status under the Fair Labor Standards Act, the Family and Medical Leave Act, and the Migrant and Seasonal Agricultural Worker Protection Act. After OIRA completes its review of the draft rule—which can take several weeks—WHD will publish the final rule. If the rule is finalized as proposed, the DOL would adopt an “economic realities” test for evaluating independent contractor status that focuses on two core factors: the nature and degree of control over the work and the worker’s opportunity for profit or loss.

‘No Taxation Without Representation.’ The Stamp Act Congress began this week in 1765 in New York City. Attended by twenty-seven merchants, lawyers, and landowners from the thirteen colonies—many of whom would go on to sign the Declaration of Independence and attend the 1787 Constitutional Convention—the Congress sought to develop a unified strategy in response to Britain’s recent passage of the Stamp Act of 1765. Directed specifically at the American colonies, the Stamp Act was designed to raise revenue to cover the costs of stationing British troops in the colonies. As a result, colonists were taxed on nearly every paper they used, including newspapers, books, court documents, commercial papers, deeds, and even playing cards and dice. After eighteen days, the Congress produced the Declaration of Rights and Grievances, which contained fourteen statements. Two of these statements would feature prominently in the subsequent fight for independence and the drafting of the United States Constitution: no taxation without representation and the right to trial by jury.

Quick Hits

• Germany’s Federal Labor Court held in a recent decision that if the body with authority to represent the company authorizes individual members to represent the company alone, the termination notice may be rejected if proof of that authorization is not attached.
• A rejection within one week is generally still considered prompt.

The Case—Termination by Two of Three Supervisory Board Members

The parties disputed the validity of two termination notices. The managing director of the defendant limited liability company (Gesellschaft mit beschränkter Haftung (GmbH)) was employed as managing director under an employment agreement. The company’s articles of association provide for a supervisory board (Aufsichtsrat) responsible for appointing and removing managing directors and for concluding and terminating their employment agreements.

The three-member supervisory board unanimously resolved to remove the managing director and terminate the managing director’s employment relationship. In a letter dated August 11, 2023, the company gave ordinary notice of termination. The termination notice, however, was signed by only two of the three supervisory board members—including the chair—and no proof of authority for the two acting supervisory board members was attached. The managing director received the termination notice on August 14, 2023, and was removed as managing director at the same time.

On August 18, 2023, the managing director rejected the termination notice because no proof of authority had been submitted and challenged the authority of the two signatories. The managing director filed a lawsuit challenging the termination of the employment relationship. On December 7, 2023, the company, in a pleading transmitted electronically to the Labor Court (Arbeitsgericht), terminated the employment relationship without notice as a precautionary measure. After the company had disputed the existence of an employment relationship before the labor court, it no longer disputed it on appeal.

The Decision—No Proof of Authority, Terminations Invalid

The BAG affirmed the lower courts’ decisions and held both termination notices invalid.

In this case, the BAG found that an employment relationship existed because the company no longer disputed its existence, at least on appeal.

The first, ordinary termination was invalid because the managing director promptly rejected it by analogous application of Section 174 sentence 1 of the German Civil Code (Bürgerliches Gesetzbuch (BGB)). No authorization for the two acting supervisory board members had been presented to the managing director, and the managing director had not previously been informed of such authorization.

The authority to remove and discharge managing directors had been transferred by the company’s articles of association to the supervisory board as a whole. No authorization existed for the two acting supervisory board members to act on behalf of the supervisory board. The supervisory board resolution, which at most could have implicitly granted such authorization, had also not been presented to the managing director.

The company had not informed the managing director of such authorization either, by analogous application of Section 174 sentence 2 BGB.

In the BAG’s view, the rejection on August 18, 2023—four days after the termination notice was received—was prompt. Only after more than one week has elapsed is a rejection no longer prompt absent special circumstances of the individual case.

The subsequent extraordinary termination without notice was invalid for lack of proper form. A termination contained in a pleading transmitted electronically does not satisfy the written-form requirement. Section 46h of the German Labor Court Act (Arbeitsgerichtsgesetz (ArbGG)), under which a termination contained in a pleading now generally satisfies the written-form requirement, did not enter into force until July 17, 2024.

Takeaways

Although the present case concerned the discharge of a managing director, for which the supervisory board was responsible, the BAG’s reasoning is relevant to employee discharges as well. In that context, the decision indicates that original proof of authority is required if, under a joint-representation arrangement, only one managing director without sole authority to represent the company signs the termination notice. Without such proof, the termination notice may be rejected. A prompt rejection would render the termination invalid for lack of proof of authority.

Ogletree Deakins’ Berlin office will continue to monitor developments and will post updates on the Cross-Border and Germany blogs as additional information becomes available.

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Quick Hits

• The EEOC has submitted a draft to rescind its 2012 enforcement guidance related to using arrest and conviction records in employment decisions.
• The 2012 guidance indicated that an employer’s use of criminal history information in employment decisions could implicate Title VII of the Civil Rights Act of 1964 under disparate treatment or disparate impact theories.
• The federal government has signaled its intention not to pursue enforcement of federal anti-discrimination laws based on disparate impact theories.

The 2012 guidance, “Enforcement Guidance on the Consideration of Arrest and Conviction Records in Employment Decisions under Title VII of the Civil Rights Act,” stated that employers using criminal background information to make employment decisions might violate Title VII either by disparate treatment (intentional discrimination based on a protected characteristic) or disparate impact (when a facially neutral policy or practice disproportionately affects one or more protected groups, even without intent).

The 2012 guidance indicated that employer use of criminal histories might have a disparate impact based on race and national origin, most notably on Black and Hispanic applicants and employees. It affirmed that the traditional three-part framework for establishing a disparate impact case applies in the criminal background check context:

• First, a plaintiff must identify a particular practice (such as an employer’s background check program) and establish that it causes a disparate impact.
• Then the burden shifts to the employer to show the practice is job-related and consistent with business necessity. Although the guidance set out two ways employers could establish this defense, most employers opted to do so using the targeted screen method, i.e., establishing that the employer considered (1) the nature and gravity of the offense; (2) the amount of time that has passed since the offense or completion of the sentence; and (3) the nature of the job held or sought. The guidance listed nine individualized assessment factors for employers to consider after an applicant or employee received an opportunity to address the criminal history. For example, an employer seeking to hire school bus drivers might demonstrate a business necessity for excluding applicants with recent prior convictions for driving under the influence or for distributing child pornography. Many employers have used the three Green factors (named for a federal circuit court case) plus the nine individualized assessment factors for more than fourteen years.
• Once an employer establishes that a background check program or practice is job-related and consistent with business necessity, a plaintiff still may prevail by identifying a less discriminatory alternative.

Beginning in 2025 and continuing in 2026, the federal government has pivoted away from enforcing employment laws based on disparate impact theories.

Expected Impact of the Guidance Rescission

Based on executive branch past practice, it is very possible (perhaps even likely) that the EEOC will rescind the 2012 guidance and not reissue any new guidance on employment-related criminal background checks. If that occurs, the rescission may have an impact on some legal theories under Title VII.

If the guidance is rescinded, background-check disparate-treatment allegations (e.g., evaluating or treating one applicant more harshly than another applicant based on the first applicant’s protected characteristic) should continue to be viable.

Although the EEOC likely would continue not to pursue disparate impact charges (opting instead to issue right-to-sue letters), disparate impact allegations based on criminal histories would continue in private lawsuits, as disparate impact is based on Title VII and well-established case law, not on executive agency decision-making or guidance. However, rescission of the 2012 guidance could indirectly affect private lawsuits because employers may argue that the rescission undercuts a Title VII disparate impact claim, while private plaintiffs may argue that the rescission does not impact existing Title VII disparate impact case law. Interpretive case law would have to fill in the gaps.

Additionally, the guidance recission would not impact the federal Fair Credit Reporting Act (FCRA), which imposes procedural and substantive requirements on employers using background checks obtained from third-party vendors, or state and local background check laws governing the use of criminal history information, which would continue to be enforced by agencies other than the EEOC and/or private plaintiffs. In fact, recent moves by some state agencies have made clear they are prepared to fill in the gap created by the EEOC’s decision not to pursue disparate impact claims. State and local background check laws, which have proliferated in recent years, vary widely in their restrictions and requirements, including when employers may conduct background checks and which types of criminal history may be considered in taking adverse employment actions. This patchwork of requirements may make compliance particularly challenging for multistate employers.

Next Steps

If the 2012 guidance is rescinded, the EEOC likely will continue to pursue enforcement of cases involving disparate treatment, but not disparate impact, in the use of criminal background checks in employment. Plaintiffs, on the other hand, likely will continue to bring private lawsuits alleging Title VII discrimination based on both disparate treatment and disparate impact claims. The guidance recission is not expected to directly impact the federal FCRA or state or local laws governing the use of criminal history information.

Employers may wish to stay abreast of any EEOC final rules, review their written policies to ensure compliance with state and local laws regarding background checks, and consider training hiring managers to stay compliant with background check laws.

Ogletree Deakins’ Background Checks Practice Group will continue to monitor developments and will provide updates on the Background Checks and Employment Law blogs as additional information becomes available.

In addition, the Ogletree Deakins Client Portal provides subscribers with timely updates on federal and state Background Check laws, as well as those of major localities. Subscribers have access to comprehensive law summaries, policies, and templates. Snapshots and Updates are complimentary for all registered client users. For more information on the Client Portal or a Client Portal subscription, please email clientportal@ogletree.com.

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

Stephen R. Woods is a shareholder in Ogletree Deakins’ Greenville office.

Gustavo A. Suárez is senior counsel in Ogletree Deakins’ Greenville office.

Amie M. Willis is compliance counsel in Ogletree Deakins’ Atlanta office.

This article was co-authored by Leah J. Shepherd, who is a writer in Ogletree Deakins’ Washington, D.C. office.

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Quick Hits

• Under SB 951, Cal/WARN notices for job losses caused in whole or in substantial part by AI or other automated technology must include four additional items: (1) the number of affected layoffs (with classifications or occupations and work locations); (2) the job functions that will be automated; (3) the category or type of technology involved; and (4) at the top of each covered notice, the following technology-displacement statement: “This notice is for a technology displacement.”
• The Employment Development Department will publish a summary of the notices it receives on its website, along with a quarterly statewide summary of reported technological displacements.
• SB 951 takes effect on January 1, 2027.

Background: The Existing Cal/WARN Act

The Cal/WARN Act already requires employers to provide sixty days’ notice of: (a) cessations or substantial cessations of operations at covered establishments; (b) mass layoffs affecting fifty or more employees at covered establishments; and (c) relocations of all or substantially all employer operations at a covered establishment by one hundred or more miles. A “covered establishment” is any industrial or commercial facility (or part thereof) that employs or has employed seventy-five or more persons at any point in time within the past twelve months. Cal/WARN notices must be provided to the affected employees, the EDD, the local workforce development board, and certain local officials. Employers that fail to give the required notice may be liable to affected employees for back pay and benefits and face a civil penalty of up to $500 for each day of the violation.

Highlights of SB 951

New notice content: SB 951 applies when a mass layoff, relocation, or termination is “caused in whole or in substantial part by” an AI system or other automated technology replacing or automating employment positions. In those cases, the employer’s Cal/WARN notice must include, in addition to the content already required: (1) the number of layoffs substantially attributable to replacement or automation by AI or other automated technology, including the classifications or occupations and work locations involved; (2) the job functions performed by affected workers that will be automated; (3) the specific category or type of AI system or other automating technology that substantially resulted in the technological displacement; and (4) the statement “This notice is for a technology displacement” at the top of the notice.

Definition of AI: SB 951 defines “artificial intelligence” as “an engineered or machine-based system that varies in its level of autonomy and that can, for explicit or implicit objectives, infer from the input it receives how to generate outputs that can influence physical or virtual environments.” This definition is broad and may reach workforce software that employers do not ordinarily think of as AI.

Public reporting: The EDD must publish a summary of the technology displacement notices it receives on its website and post a quarterly statewide summary of the technological displacements reported.

Legislative report: By January 1, 2028, the EDD must submit a report to the legislature on AI’s effects on business hiring practices, including its impact on industries and occupations at the state and regional levels. The requirement to submit that report will be repealed on January 1, 2029, but it signals that a broader AI-related notice requirement could follow.

Next Steps

Employers planning workforce reductions, relocations, or closures in California may want to consider the following steps before January 1, 2027:

• Updating existing Cal/WARN notice templates.
• Documenting the extent to which AI or automated technology contributed to the elimination of specific positions or functions, in order to evaluate whether the “in whole or in substantial part” trigger is met.
• Ensuring that legal, HR, technology, and communications teams coordinate their work so that the reasons stated in Cal/WARN notices align with reduction in force documentation and internal/external communications.

Ogletree Deakins’ California offices and RIF/WARN Practice Group will continue to monitor developments and will provide updates on the Artificial Intelligence and Innovation, California, and Reductions in Force blogs as additional information becomes available.

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