Federal Contractor Minimum Wage Executive Order Revoked

Employees of federal contractors are no longer entitled to special federal minimum wage rates for work performed on, or associated with, certain federal contracts. On March 14, 2025, President Donald Trump issued an Executive Order (EO) titled, “Additional Rescissions of Harmful Executive Orders and Actions”, which repealed approximately twenty memoranda and executive orders issued by former President Joe Biden. Included among those revoked was Executive Order 14026, titled “Increasing the Minimum Wage for Federal Contractors.” EO 14026 applied to new or renewed federal contracts after January 30, 2022, and mandated that federal contract employees receive a minimum wage of $15.00 per hour. EO 14026 automatically increased the federal contractor minimum wage to $17.75 per hour in January 2025. The United States Supreme Court declined to address specifically whether former President Biden possessed the authority to mandate such wages.

In light of President Trump’s revocation of EO 14026, it is currently unclear to what extent the United States Department of Labor will repeal or amend the regulations implementing EO 14026. However, given that the underlying authority of the regulations has been revoked, such regulations will likely not be enforced, and federal contractors will not be required to pay employees the heightened minimum wage. Nevertheless, federal contract employees would still be covered by federal and state minimum wage statutes, as well as the Department of Labor’s prevailing wage rates, which set certain minimums according to job classification.

Prior to EO 14026, former President Barack Obama had raised the minimum wage for federal contract employees through EO 13658 to $10.10, with periodic increases, the latest of which was $13.30. Former President Biden’s EO 14026 replaced former President Obama’s mandate but did not repeal it. Thus, with respect to federal contracts entered into prior to January 30, 2022 (effective date of EO 14026), federal contractors will be required to pay employees at least $13.30 per hour.  As for federal contracts formed or renewed after January 30, 2022, federal contractors must pay employees the federal minimum wage ($7.25 per hour) or the state minimum wage, should it exceed $7.25 per hour. Finally, federal contractors must also be cognizant of, and comply with, the Department of Labor’s applicable prevailing wage rates.

If you are a federal contractor and have questions about how to remain compliant with applicable wage laws, please reach out to your Dinsmore & Shohl LLP labor and employment attorney.