Update Applicable to:	Effective Date
All Covered Employers	July 1, 2025

What happened?

On July 1, 2025, the Minnesota Department of Human Rights (MDHR) implemented administrative updates to its affirmative action compliance process for government contractors, revising documentation and reporting requirements to align with federal directives and reduce legal risk.

Overview:

1. Workforce Certificate Application (Updated in March 2025)

• Removed references to demographic workforce goals and the Office of Equity and Inclusion.
• Now requires agreement to a Good Faith Efforts checklist.
• Signature by the CEO/president is no longer required.
• Emphasizes compliance with the Minnesota Human Rights Act.

2. Compliance Plan (formerly Affirmative Action Plan – Renamed and revised in April 2025)

• Removed references to affirmative action goals, definitions, and business utilization targets.
• Added a new Anti-Discrimination Policy and clarified the role of the Equal Employment Opportunity (EEO) Official.
• Focus shifted from affirmative action to Equal Employment Opportunity (EEO).

3. Nondiscrimination Poster

• New title: “Our Commitment to a Workplace Free from Discrimination.”
• Adds protection for local human rights commission activity.
• Removes all references to affirmative action.

4. Annual Compliance Report (ACR)

• Must be submitted annually, even without active contracts.

• Now split into two parts:
  • Part 1: Narrative – Describes implementation of the Compliance Plan and EO Statement, and any corrective actions.
  • Part 2: Data Analysis – Includes workforce data and underutilization analysis using 2018 Census data.

• Goal setting is no longer required.

• Reporting period must now exactly match the certificate anniversary date.

5. Timing Guidance

• New ACR date rules apply to certificates approved after July 1, 2025.
• Certificates approved before that date follow the current method until expiration.

Source References

• MDHR – Workforce Certificate Application Form Step-by-Step Guide
• MDHR – Annual Compliance Report (ACR)
• MDHR Poster – Our Commitment to a Workplace Free from Discrimination
• MDHR – Nondiscrimination Poster.

Resources

• MDHR – Compliance Plan Word Doc

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