Introduction

For Black Americans, public-sector employment has historically provided a pathway to better, more equitable and secure job opportunities compared with available private-sector jobs. The federal government has played an especially vital role in establishing a robust Black middle class in the Washington, D.C. metro area. According to the 2023 American Community Survey, roughly 2 out of 5 Black adults in the D.C. metro area were college graduates, Black median household income was nearly $90,000 and the Black homeownership rate was 52.8%. Postal service jobs have been particularly valuable to Black workers without college degrees because of the uniform wage and benefit structure (all postal employees who have the same job title and job tenure are paid the same nationwide) and higher pay relative to comparable private-sector employment. With a minimum education requirement of a high school diploma, the median hourly wage of a postal worker is 43% higher than the typical high school graduate. While federal employment has opened the door to social and economic mobility for generations of Black Americans, it has often been the battleground and served as a compass in setting higher labor standards and equal employment policies in the United States.

Opportunity. Backlash. Resistance. Change: A brief history of Black federal workers

The history of Black workers employed in the federal government dates to the Civil War when the federal government hired its first Black employee in the Treasury Department in 1863. In time, the federal government quickly became the largest employer of formerly enslaved people, with large concentrations in the military and the U.S. Postal Service (USPS). By 1912, the federal government was the largest employer of Black Americans in the nation, including highly skilled Black workers who were hired in high-ranking white-collar positions.

One of the earliest actions aimed at weakening the position of Black federal workers came shortly after the inauguration of President Woodrow Wilson. In 1913, Wilson racially segregated the USPS and Treasury department—the first federal agencies to employ, and in the case of USPS, promote Black workers to management positions. The administrative practice of segregating the federal workforce extended to the demotion of Black civil servants from white-collar positions, at-will firings, and refusal to fill open jobs with qualified Black candidates. Later that year, a group of Black workers formed the National Alliance of Postal Employees, the first industrial union in the federal service, to resist the administration’s racist tactics.

In the 1940s and 1950s, Presidents Franklin D. Roosevelt, Harry S. Truman, and Dwight D. Eisenhower each issued executive orders that took measured steps to undo the overtly racist and discriminatory federal employment practices put in place by Wilson. Those orders were largely directed at national defense industries, armed forces, and government contractors in response to the demands imposed by World War II. But, throughout the 1950s and 1960s, civil rights activists pushed the federal government to do more to expand its hiring of Black workers. In response, President Eisenhower’s Executive Order 10590 established the President’s Committee on Government Employment Policy (PCGEP) in 1955. The PCGEP involved federal agencies more fully in the government’s anti-discrimination agenda and called for departments to develop regulations in accordance with its mission to stop all discrimination in all federal employment. However, the group lacked the enforcement power necessary to accomplish that mission.

Over the following decades, job prospects for Black federal workers were most improved by a series of executive actions and legislation introduced in the 1960s and 1970s. On March 6, 1961, President John F. Kennedy’s Executive Order 10925 required the federal government and federal government contractors to practice non-discrimination in their hiring practices. Additionally, E.O. 10925 established the President’s Committee on Equal Employment Opportunity (PCEEO) to monitor non-discrimination on government contracts. In a move that distinguished the PCEEO from prior ineffective, enforcement-lacking efforts like Eisenhower’s PCGEP, Kennedy granted policy-making authority to the group led by Vice President Lyndon Johnson and Secretary of Labor Arthur Goldberg.

On January 17, 1962, Kennedy signed Executive Order 10988 which allowed limited collective bargaining for federal employees for the first time and opened the door to federal employee union membership under three different classifications: informal, formal, and exclusive recognition. Public-sector collective bargaining would play a central role in maintaining the quality and accessibility of federal jobs through labor contracts that fostered transparency with clearly defined policies and pay structures. Labor contracts also served to limit discriminatory outcomes while providing critical protections and recourse against other forms of exploitation or mistreatment.

The power of Kennedy’s executive orders was reinforced when Title VII of the historic Civil Rights Act of 1964, signed by President Lyndon Johnson, formally prohibited employment discrimination in the United States and established the Equal Employment Opportunity Commission (EEOC) to enforce the law. The Equal Employment Opportunity Act of 1972 extended Title VII protections to cover more employers and strengthened the enforcement power of EEOC by allowing them to litigate against employers, including federal agencies, who violated Title VII.

Within the span of the 1960s and 1970s, the federal government had established a clear definition of what it meant to be an equal opportunity employer, leveraged its purchasing power to compel private contractors to meet similar standards, extended limited collective bargaining rights to federal workers, and assigned the EEOC a central role in enforcing anti-discrimination law. Black federal employees also continued to support and advocate for one another, establishing the non-profit organization, Blacks in Government (BIG), in 1975. The progress made during 1960s and 1970s would be gradually chipped away in the decades that followed. 

Federal job losses since the 1980s

During the 1980s, the Reagan administration took a swipe at federal employees, unions, and anti-discrimination enforcement, but that record pales in comparison to more recent developments. While Reagan announced plans to make federal job cuts, and infamously fired 11,000 striking air traffic controllers in the early 1980s, federal payrolls actually rose by more than 200,000 during his presidency before dropping by 427,000 during the 1990s and taking another hit of 244,000 between 2010 and 2014. Since the 1980s, the postal service, a major employer of Black workers, has been under sustained assault, including attempts to undercut employee compensation and the agency’s solvency.

In 2025, the Trump administration took steps to implement massive cuts to the federal sector and reverse course in the government’s pursuit of equity by rescinding at least a dozen prior executive orders related to racial and/or gender equality and terminating workers in DEI departments within federal agencies. In a series of legally challenged actions, Trump fired decisionmakers at the EEOC and National Labor Relations Board (NLRB)—rendering two independent agencies responsible for enforcing workers’ rights non-operational for several months—while his newly created Department of Government Efficiency (DOGE) made severe staff reductions and eliminated entire federal agencies. Trump’s attacks on the federal workforce have also included attempts to limit the approval of collective bargaining agreements with federal workers. The actions of Trump and DOGE contributed to the loss of 288,000 federal jobs between January and December of 2025, based on data from the Bureau of Labor Statistics. Ironically, while federal jobs once provided Black workers relatively more job security, early evidence suggests the burden of federal job cuts has fallen disproportionately on Black women. The potential consequences of these actions go beyond job losses and include major implications for Black family incomes and racial and gender pay equity.

An accounting of the significance of federal sector employment for Black workers and families

As detailed in the history presented above, between 1941 and 1981, Black workers gradually improved their employment status in the federal government through collective and individual activism of groups like the National Alliance and Blacks in Government, within a context of official support for their rights through executive orders and landmark civil rights legislation. This improved employment status expanded the ranks of Black federal workers who were able to secure higher incomes. By 1970, the median household income for Black families was just $6,279 compared with a range of $7,178–$10,987 for those earning GS 5–8 salaries in the federal government. In fact, Black federal employees compensated between grades GS 5–8 were either close to or slightly above the national median of $9,867. This remains a factor today as the high concentration of federal employment and related professional job opportunities in the Washington, D.C. metro area helps to make metro D.C.’s Black median household income ($89,912 in 2023) one of the highest in the nation and well above the overall national median of $77,719.

Analysis of 2024 state-level data from the Office of Personnel Management (OPM) reveals that over 300,000 federal workers (excluding USPS) reside in the D.C. metro area, accounting for 60% of all federal workers in the District of Columbia and surrounding states of Virginia, Maryland, and West Virginia. Black workers are just over one-fourth of the federal workforce in the District of Columbia (28.8%), Maryland (27.9%), and Virginia (26%). While the D.C. metro area is home to the largest concentration of federal workers, over 90% of the federal workforce live and work outside the nation’s capital. Black workers account for at least one-fifth of the state’s federal workforce in 12 states beyond the D.C. metro area.

Implications of massive federal job losses and the unfinished business of equity

To understand the stakes of federal workforce contraction, it is necessary to compare the demographic and wage structure of federal employment with that of the broader labor market. As shown in Table 1, in 2023 and 2024, Black workers were 12.5% of the private-sector workforce, compared with more than a fifth (22.6%) of all workers in the federal sector—a share that also exceeds their representation in the entire public sector (16.4%) which includes state and local governments. Black women’s share of the federal workforce (12.8%) was double their share in the private sector (6.4%).

A national comparison of hourly wages at the median and for low-wage (10th percentile) workers demonstrates the clear monetary benefit of federal over private-sector employment. Figure A shows this is true across race and gender both at the middle and lower end of the wage distribution. The hourly wage of a typical (i.e., median) Black federal worker is more than 40% higher than that of the median Black worker in the private sector. Black federal workers—median and 10th percentile—also have higher wages than same gender white workers in the private sector. It is worth noting that these wage comparisons don’t account for the more generous benefits typically offered to federal and other public-sector workers, which further raises the value of their total compensation. The higher wages earned by federal workers largely reflect the higher share of college and advanced degree holders and higher rates of union coverage relative to private-sector employees. Less than 7% of private-sector workers are in a union or covered by a union contract compared with 35.9% of all public-sector workers and 29.5% of federal workers (see Table 1). While greater union coverage helps to boost wages and benefits for all workers, it is an even more important factor in raising wages of those for whom racial and gender discrimination further restrict individual bargaining power.

Another factor contributing to better pay outcomes in the federal government is the use of the Schedule (GS) pay scale which applies to over 70% of white-collar federal jobs. This helps to mitigate pay discrimination in the federal government by standardizing the qualifications and compensation associated with a specific position and consistent with experience, job performance, and local cost of living. On average, Black federal workers appear to experience only marginally improved pay equity over Black workers in the private sector, while the Black-white wage gap is much smaller in the public sector, overall.

In the federal sector, Black workers earn 12.6% less than white workers with the same levels of education, experience, union coverage status, gender, and state of residence, compared with 14.9% less in the private sector and just 3.8% less in the overall public sector (see Table 2). Although there is a sizable wage gap between Black women and white men across sectors, the federal sector gap (26.1%) is nearly 8 percentage points lower than the gap that exists in the private sector (33.9%). Given enforcement of the GS pay scale, remaining racial and gender pay gaps among federal workers likely reflect disparities in job positions and associated GS levels, a long-documented concern of Black federal worker advocates and activists. These disparities may stem from the underrepresentation of Black workers in higher-level, higher-paying positions, which can reflect differences across agencies in workforce demographic composition, occupational structures, and promotion rates. Notwithstanding the relatively higher economic position of many Black federal workers, these results epitomize the unfinished business of eliminating pay inequity and occupational segregation across all sectors of the labor market.

Conclusion

This brief summarizes the important role federal-sector employment has played in providing better job opportunities for Black Americans than have traditionally been available in the private sector. However, those outcomes have never been a given. A solid history of advocacy and activism by and on behalf of Black federal workers alongside others were critical in securing important wins through executive actions and policy change. Moreover, pushback against some of the most egregious violations of federal worker’s civil and worker rights have at times resulted in stronger, more broadly enforced labor and equal employment standards, improving outcomes to the benefit of all workers.

Key takeaways

• The 2025 Census data on earnings, income, and poverty may reflect how the Trump administration’s policy choices were beginning to impact the economic well-being of workers, families, and children last year.
• Last year’s economy was characterized by slowing job growth, rising wage inequality, and growing policy uncertainty. We expect to see little to no improvements in key economic indicators such as lower-end household income and supplemental poverty rates between 2024 and 2025.
• The 2026 story is still unfolding and is likely to be worse, given these factors: decelerating nominal wage growth, higher inflation, and the 2025 budget reconciliation law that will leave more families and children vulnerable to poverty.

Next week, the Census Bureau will release the latest data on earnings, income, and poverty for 2025. This data could show early signs of how the Trump administration’s policy choices impacted the economic well-being of workers, families, and children across the country. The initial strong recovery from the pandemic recession measurably slowed in 2025 as the labor market softened and the policy climate grew more uncertain. To help place the upcoming data release in context, we highlight key trends that have characterized the economic and policy landscape in 2025. Though the economy continued to soften as inflation worsened in 2026 and the safety net grew increasingly more difficult to access as a result of the Republican Budget Reconciliation Law, the data in the Census will only provide specific insights for living standards in 2025.

In summary, we find:

1. 1. The U.S. economy in 2025 grew more slowly than in 2024, adding fewer than half as many jobs—only 764,000 jobs compared with 1.825 million in 2024. The unemployment rate slowly rose over the course of 2025, and the hires rate was depressed, making it harder for young people in particular to break into the labor market. While the prime-age employment-to-population remained relatively resilient to labor market softening, prime-age Black workers experienced large declines in their employment rate.
   2. With more moderate inflation, strong nominal wage growth translated into decent average hourly wage gains between 2024 and 2025, but gains were not shared equally. Lower-end wage growth stalled in 2025, which could have implications for lower-end incomes and poverty rates.
   3. Because the Republican budget reconciliation law is making basic needs programs like SNAP increasingly more difficult for families to access, we don’t expect to see any significant improvements in supplemental poverty between 2024 and 2025. We expect to the see the full impact of the Republican law in the years ahead.
   4. While the release will only provide data for 2025, our examination of the economic and policy landscape for 2026 suggests that a weaker job market, safety net cuts, and high inflation will worsen outcomes.

The labor market recovery softened in 2025

Because the vast majority of people in the United States rely on labor market income for their economic well-being, the labor market data we already have for 2025 should provide some insights into what the Census data may tell us. Overall, job growth has slowed, and the unemployment rate has ticked up as employment rates softened, particularly for certain demographic groups.

After the tremendous rebound from the pandemic recession, the labor market cooled somewhat. Payroll employment growth went from 3.3 million in 2023 to 1.8 million in 2024 and then 764,000 in 2025. A slowdown would be expected after such a strong recovery, and the number of jobs needed to keep up with population growth declined with lower net immigration in the wake of Trump’s draconian mass deportation policies. Nearly 100,000 federal jobs (96,000) were lost in the massive DOGE cuts (when comparing annual averages, which obscure more massive downward trends later in the year), and even manufacturing employment faltered in Trump’s first year, falling by 156,000 jobs between 2024 and 2025. If not for job growth in health care and social assistance, overall payroll employment would have fallen outright.

This weakening led to a mild increase in the unemployment rate, from 4.0% to 4.3% between 2024 and 2025. Figure A displays the change in some key labor market indicators for certain demographic groups. While the overall unemployment rate rose modestly, the increase was far greater for young workers, ages 16 to 24. It’s likely that the depressed hires rate has made it harder for young workers to break into the labor market. Older workers experienced much milder increases in their respective unemployment rates.

The share of the population with a job—the employment-to-population ratio fell from 60.1% to 59.7%, a drop of 0.4 percentage points. Prime-age workers—those between 25 and 54 years old—were more resilient to the labor market softening. However, prime-age Black workers experienced a tremendous decline of 1.3 percentage points between 2024 and 2025. This weakness may show up in the income and poverty data released next week. At the same time, prime-age Hispanic workers experienced an increase in their employment-to-population ratio.

Figure A

Wage inequality increased in 2025

Employment changes alone have important implications for family and household income, but wages are also an important part of the economic story. Figure B illustrates several key price and wage changes between 2024 and 2025. Though the economy was a bit weaker, the labor market delivered strong nominal wage growth for private-sector workers, measured by the Current Employment Statistics. Nominal average hourly wages increased 4.0% between 2024 and 2025. Inflation moderated—remember this is before the spike in 2026—and therefore, real hourly wages rose a modest 1.5%.

Unfortunately, the gains were not broad based. Unlike the faster wage growth among lower-wage workers through 2024, lower-end wage growth stalled in 2025. While the fall wasn’t large, it reversed the trends experienced between 2019 and 2024. The stair-step increase in wage growth, as shown in the right half of Figure B, suggests a return to a K-shaped recovery, wherein higher-wage workers experienced much faster wage growth than those at the middle or the bottom. While stronger average wage growth and modest median wage growth may suggest modest improvements in median household income—though tempered by slower job growth—weaker low-end wages may translate into losses for lower-income households and possibly rising poverty rates, particularly for groups hit hardest by falling employment.

Figure B

Republicans weakened SNAP last year and any chance at poverty alleviation in the years ahead 

The end of the expanded social safety net in 2022 eroded all of the gains in poverty reduction experienced between 2020 and 2021. Since 2022, poverty has continued to climb. This unfortunate trend in poverty is unlikely to reverse course in the latest Census release for 2025. This is partly because the Republican budget reconciliation bill signed into law by President Trump in July of last year significantly cut and limited access to basic needs programs like SNAP, one of the most successful programs in our country’s fight against poverty and hunger. Because the implementation of these changes and spending cuts is still ongoing, we are unlikely to see the full impact of the Republican law in next week’s data.

In 2024 alone, SNAP lifted more than 3.5 million people out of poverty. Nearly 40% of these individuals were children (see Figure C). In fact, both SNAP and the National School Lunch Program (NSLP), which provides reduced-cost or free lunches to low-income children in public and nonprofit private schools, lifted more than 2 million children out of poverty in 2024. After refundable credits, these programs, along with Social Security, make up the most effective anti-poverty strategies for children in the United States.

Figure C

Instead of strengthening the country’s nutritional assistance programs to improve access and the adequacy of benefits amid growing food insecurity, the Republican reconciliation package cut funding for the U.S. Department of Agriculture (USDA), imposed strict and costly work requirements, and eliminated waivers for areas with chronically high unemployment. The ongoing implementation of some of these changes, including factors associated with staff limitations, has led to a decline in SNAP participation by more than 4.5 million people. This drop will not be entirely reflected in the upcoming poverty statistics since some of this decline occurred in 2026. Yet the cutting back of resources for USDA and SNAP initiated by congressional Republicans and the administration will continue to translate into higher poverty rates and increased food insecurity, as states struggle to implement the costly and harmful changes now required by the new law.

The administration has also taken steps to ensure that we don’t have the data we need to trace the painful impact of these changes on food insecure families. In September 2025, Trump’s USDA canceled the country’s leading survey that documented the magnitude and severity of hunger and food insecurity in the U.S. They claimed that the USDA survey and report  were “redundant” and “politicized.” Soon after this, the administration allowed SNAP benefits to lapse for the first time in the history of the program, while at the helm of the longest full government shutdown in U.S. history, lasting 43 days and creating a chaotic situation for SNAP beneficiaries, many of whom needed to turn to food pantries for help. 

As we will be reminded when the Census releases its poverty statistics for 2025, the impact of all these harmful policies hit Black and brown families with children particularly hard. This is because families of color are disproportionately more likely to rely on SNAP to avoid food insecurity, and children of color are also more likely to be burdened by poverty than their peers.

In 2021, the United States demonstrated to the world that it had the capacity to reduce poverty to historically low levels by expanding access to SNAP and other basic needs programs. In 2025, Trump and congressional Republicans showed the world that they were willing to gut basic needs programs to pay for tax cuts that disproportionately favor the wealthy. We should not be surprised when we fail at poverty reduction in the years ahead.

Next week’s data will be about the economic story of 2025. The 2026 story is still unfolding and is likely to have a worse ending.

As noted earlier, the earnings, income, and poverty statistics the U.S. Census will publish next week are for 2025. While we don’t yet know the full economic story for 2026, it is unlikely to be a more promising one. This is because the slowdown in job growth that began in 2025 has further solidified throughout 2026. This weaker job market continues to be particularly harmful to Black and young workers. The softer labor market in 2026 has also coincided with worsening inflation. Higher inflation is largely due to Trump’s ongoing war in Iran, which has already wiped out 1.5 years of real wage growth in a matter of months.

The policy landscape for 2026 also looks bleaker. The spending cuts to the U.S. social safety net that Trump signed into law in the summer of 2025 will continue to hurt the ability of families to access basic services like Medicaid and SNAP. This will leave increasingly more economically insecure families vulnerable to poverty and unnecessary hardship in the face of a worsening affordability crisis.

Raymond Windmiller, Executive Officer
Executive Secretariat
U.S. Equal Employment Opportunity Commission
131 M Street, NE
Washington, DC 20507

Re: Proposed Rule for Removal of Reporting Requirements (RIN 3046-AB37)

Dear Commissioners,

I write to submit this comment on behalf of the Economic Policy Institute (EPI), responding to the Equal Employment Opportunity Commission’s proposed rule to rescind and remove the requirements for filing the EEO-1, EEO-2, EEO-3, EEO-4, EEO-5, and EEO-6 reports1, and the recordkeeping and record preservation requirements related to these reports, under 29 CFR part 1602.

EPI is a nonprofit, nonpartisan think tank created in 1986 to include the needs of low- and middle-income workers in economic policy discussions. EPI conducts research and analysis on the economic status of working America, proposes public policies that protect and improve the economic conditions of low- and middle-income workers, and assesses policies with respect to how well they further those goals. For 18 years, EPI’s Program on Race, Ethnicity and the Economy (PREE) has been a nationally recognized source for expert analysis of the many ways that race, ethnicity, gender, class and policy decisions intersect to affect economic outcomes.

We strongly oppose the EEOC’s proposal to rescind the EEO reporting, recordkeeping and record preservation requirements. If implemented, this rule would undermine the Commission’s capacity to enforce federal laws against employment discrimination. Furthermore, this rule would deprive employers, researchers, policymakers and advocates of their ability to independently analyze and use this unique data source to develop and advocate for policies that support the EEOC’s mission of ending workplace discrimination.

The U.S. Equal Employment Opportunity Commission (EEOC) is a cornerstone in upholding the civil rights of U.S. workers. Established under the same law that officially prohibited employment discrimination (Title VII of the Civil Rights Act of 1964), the EEOC embodies the fact that effective federal laws against employment discrimination require consistent enforcement. For the last 60 years, EEO reports have been central to the agency’s capacity to enforce the law and to monitor and track the nation’s progress toward ending workplace discrimination.

That goal is still a work in progress, as documented in an extensive body of methodologically rigorous research by economists, sociologists and other social scientists. In what follows, we explain why the Commission’s proposal to rescind all EEO data collection would be counterproductive to reaching that goal and detrimental to the U.S. economy by:

• Summarizing the research on labor market discrimination that justifies the ongoing need for EEO reporting requirements;
• Describing how broad EEO reporting requirements help to rebalance power and information asymmetries between employers and employees; and
• Presenting estimates of how much discrimination costs the U.S. economy in economic output and average living standards.

Research and national data provide compelling evidence of persistent labor market discrimination against “minorities”

In their proposed rule, the Commission claims that EEO Reports “may encourage employers to discriminate against employees who are not considered ‘minorities,’ may promote racial stereotyping, and may encourage employers to engage in discrimination to avoid potential EEOC enforcement actions or to address perceived inequitable outcomes.” In addition to this being highly speculative, it is also inconsistent with what we know from research and national statistics. Large and persistent disparities in employment and pay of Black workers relative to white workers are among the most durable features of the U.S. labor market. Compelling empirical evidence points to discrimination as a significant factor in the persistence of those disparities.

EPI’s detailed expert analysis of Bureau of Labor Statistics (BLS) data shows that the significant racial disparities in unemployment that are observed at each level of education, across age cohorts, and among both men and women strongly suggest that education or skills differentials alone can’t account for the near constant 2-to-1 Black-white unemployment gap2.

These findings are consistent with field experiments revealing that Black job applicants with equivalent, and sometimes superior, credentials to white applicants are less likely to receive job callbacks3. One of the starkest audit study findings in this regard concludes that employers treated white applicants with criminal records more favorably than Black applicants without criminal records4. Researchers also found that when résumés of Black and Asian job applicants were stripped of clues of their racial identity, they received callbacks at a much higher rate than those that clearly indicated an applicant’s racial identity5.

While audit and correspondence studies have been criticized for not adequately capturing unobserved characteristics that might influence hiring decisions, newer studies have shown how robust these findings can be to such considerations6. In fact, subsequent field experiments reveal a pattern of hiring discrimination experienced by Black and Hispanic job seekers that remained remarkably constant over time, with white applicants receiving 36% more callbacks than Black applicants and 24% more callbacks than Hispanic applicants7.

EPI’s analysis has also shown that since 1979, less than half of the observed black-white difference in average hourly wages can be explained by differences in education, experience, or region—the main factors presumed to determine pay – and discrimination has consistently played a major role8. However, changes in this racial wage gap track closely with changes in policy, including civil rights enforcement, and with structural factors that affect wage inequality. According to trend analysis research, the narrowing of the gap from the late 1960s through the 1970s can be attributed to the passage of important civil rights legislation9, combined with the 1960s economic boom, active enforcement of anti-discrimination10 and affirmative action policy11, and the narrowing of the educational attainment gap between Black and white workers12. On the other hand, retrenchment on anti-discrimination policy was found to be a significant factor in the widening of the gap during the 1980s13. Since 2000, research has shown a troubling trend of larger discriminatory differentials among the more highly educated14.

Contrary to the Commission’s proposed justification for ending EEO reporting requirements, the research literature cited above offers no evidence of systemic discrimination “against employees who are not considered minorities”. The research, however, underscores the need for ongoing monitoring of employment and pay discrimination through the collection of EEO data.

Elimination of EEO data would worsen power and information asymmetries that undermine worker protections

In an essay published under EPI’s Unequal Power project, former EEOC Chair Jenny Yang explains that “in a system that places the primary responsibility for enforcing anti-discrimination laws on individual workers, who must file complaints with their employer or a government agency, the government plays a fundamental role in rebalancing the power disparities between workers and employers.”15 She further concludes that “policies that encourage employer transparency and require data collection to support prevention and accountability are essential to addressing the inherent information asymmetry workers face.”16

EEO data helps to provide the necessary transparency and accountability across major segments of the U.S. labor market, including private employers with 100 or more employees and federal contractors with 50 or more employees (EEO-1), apprenticeship programs (EEO-2), labor unions (EEO-3), state and local governments (EEO-4), elementary and secondary schools (EEO-5) and institutions of higher education (EEO-6)17.

While the Commission now argues that reporting requirements are too broad because they include non-discriminating employers along with those accused of discrimination, that feature is actually a strength of EEO data. As the nation’s only federally collected source of firm-level information on employment by race, ethnicity, sex, and job category, the EEO-1 provides EEOC investigators with the information they need to assess each individual claim within the context of a larger group of employers.

In addition to being used in this important first step of the charge intake process, these data can also identify potential patterns of systemic discrimination within an industry, occupation, or worksite location. This information helps to direct EEOC systemic enforcement and commissioner’s charges, enabling the EEOC to investigate and address discriminatory practices in cases where workers either lack information or fear retaliation for filing an individual charge of discrimination. Many state and local government Fair Employment Practices Agencies (FEPAs) also have data sharing agreements with EEOC, allowing them to utilize EEO data for local enforcement activities. Similar data collections are too costly for most FEPAs to undertake on their own. As such, EEO data address information and power asymmetries that make it difficult and costly for workers to identify and prove discrimination.

Elimination of EEO data would limit EEOC’s ability to support economic growth through reduced discrimination

Finally, the Commission claims that elimination of the EEO surveys is consistent with the policy underlying E.O. 14192, “Unleashing Prosperity Through Deregulation,” requiring agencies to be “prudent and financially responsible in the expenditure of funds . . . to alleviate unnecessary regulatory burdens placed on the American people.” However, the Commission is overlooking the cost discrimination imposes on the economy and the long-term consequences ending EEO data collection would have on the EEOC’s ability to reduce discrimination through the enforcement mechanisms described above.

Research shows that since the 1960s, the decline in workplace discrimination has contributed to a stronger economy and more inclusive labor force. A widely cited 2019 report concludes that reduced discrimination alone accounted for almost 8% of GDP per capita growth between 1960 and 201018. Extrapolating this estimate through 2024 and applying it to published national estimates of real GDP per capita, we estimate that reduced discrimination boosted average living standards by $4,932 per person since 196019. While it is difficult to precisely measure the EEOC’s impact apart from other forces, assuming the Commission’s role in reducing discrimination accounts for 10–25% of that growth, we estimate that EEOC enforcement, aided by EEO data, helped to boost average living standards by $493 to $1,233 per person since 1960. This estimated increase in average living standards applies to all people, not just those with proven claims of discrimination. Elimination of EEO data would compromise many of the EEOC’s tools for enforcing laws against employment discrimination, and as a result, undermine economic growth.

Conclusion

For years, the EEOC has been vastly under-resourced relative to the magnitude of its enforcement responsibilities, and EEO data is essential to directing those limited resources. Changes to the categories and definitions used in EEO forms over time represent the ways in which Commissioners have grappled with how to accurately capture individual markers of identity useful in detecting unfair influence over employment opportunities for members of legally protected classes.

Under prior administrations, EEOC has convened expert panels to evaluate EEO data collections. These panels were comprised of statisticians, economists, sociologists, legal scholars, and other practitioners with decades of expertise in statistical analysis, labor and civil rights law and the study of labor market discrimination. I have had the privilege of serving on two of these panels. In both instances, panel members expressed differing opinions with respect to data quality, what conclusions could be reliably drawn from the data, and how to best improve the data collection process. Undoubtedly, there were also likely differences in panel members’ political views, but I don’t ever recall any assertion that the problem discrimination had been sufficiently reduced to justify removal of EEO reporting requirements.

In conclusion, EPI strongly urges the Commission to withdraw its proposal to eliminate all six of the EEO surveys. Failure to do so would renege on the promise of our nation’s anti-discrimination laws for workers, their families and the economy.

Sincerely,

Valerie Wilson, PhD
Director, Program on Race, Ethnicity and the Economy
Economic Policy Institute

1. The EEO-2 remains authorized under Title VII of the Civil Rights Act of 1964 but has not been collected since 1981. In this case, our recommendation to continue the surveys is a recommendation to reinstate it.

 The EEO-6 remains authorized under Title VII but has not been collected since 1993. In this case, our recommendation to continue the surveys is a recommendation to retain this authorization and reinstate the survey to the extent that it is not superseded by the Integrated Postsecondary Education Data System (IPEDS) Staff Survey of the U.S. Department of Education.

2. Valerie Wilson and William Darity Jr., Understanding black-white disparities in labor market outcomes requires models that account for persistent discrimination and unequal bargaining power, Economic Policy Institute, March 2022.

3. Examples include: Michael Fix, George C. Galster, and Raymond J. Struyk, “An Overview of Auditing for Discrimination.” in Michael Fix and Raymond Struyk, eds., Clear and Convincing Evidence: Measurement of Discrimination in America, Urban Institute Press, 1993; Marc Bendick, Jr., Charles W. Jackson, and Victor Reinoso, “Measuring Employment Discrimination Through Controlled Experiments” in James B. Stewart, ed., African-Americans and Post-Industrial Labor Markets, Transaction Publishers, 1994; Michael Fix, George C. Galster, and Raymond J. Struyk, “An Overview of Auditing for Discrimination” in Michael Fix and Raymond Struyk, eds., Clear and Convincing Evidence: Measurement of Discrimination in America. Urban Institute Press, 1993; and Margery Turner, Michael Fix, and Raymond Struyk, Opportunities Denied, Opportunities Diminished: Racial Discrimination in Hiring, Urban Institute Press, 1991.

4. Devah Pager, “The Mark of a Criminal Record,” American Journal of Sociology 108 (March 2003): 937–75.

5. Sonia Kang, Katy DeCellesa, András Tilcsika, and Sora Jun, “Whitened Résumés: Race and Self-Presentation in the Labor Market,” Administrative Science Quarterly 61, no. 3 (March 17, 2016): 469-502.

6. David Neumark, “Detecting Discrimination in Audit and Correspondence Studies,” Journal of Human Resources 47 (Fall 2012): 1128–57. 

7. Lincoln Quillian, Devah Pager, Ole Hexel, and Arnfinn H. Midtbøen, “Meta-Analysis of Field Experiments Shows No Change in Racial Discrimination in Hiring Over Time,” Proceedings of the National Academy of Sciences 114, no. 41 (October 10, 2017): 10870-875.

8. Valerie Wilson and William Darity Jr., Understanding black-white disparities in labor market outcomes requires models that account for persistent discrimination and unequal bargaining power, Economic Policy Institute, March 2022.

9. Examples include: John Bound and Richard Freeman, “Black Economic Progress: Erosion of the Post-1965 Gains in the 1980s?” in Steven Shulman and William Darity, Jr., eds., Question of Discrimination: Racial Inequality in the U.S. Labor Market, Wesleyan University Press, 1989; David Card and Alan Krueger, “School Quality and Black-White Relative Earnings: A Direct Assessment,” Quarterly Journal of Economics 107 (February 1992): 151–200; and John Donohue and James Heckman, “Continuous vs. Episodic Change: The Impact of Civil Rights Policy on the Economic Status of Blacks,” Journal of Economic Literature 29 (December 1991): 1603–43. 

10. Examples include: Augustin K. Fosu, “Occupational Mobility of Black Women, 1958–1981: The Impact of Post-1964 Antidiscrimination Measures,” Industrial & Labor Relations Review 45, no. 2 (1992): 281–94; and James J. Heckman and Brook Payner, “Determining the Impact of Federal Antidiscrimination Policy on the Economic Status of Blacks: A Study of South Carolina,” National Bureau of Economic Research Working Paper no. 2854, 1989. 

11. Examples include: Charles Betsey, “Litigation of Employment Discrimination Under Title VII: The Case of African American Women,” American Economic Review 84, no. 2 (1994): 98–102; and Jonathan S. Leonard, “The Impact of Affirmative Action Regulation and Equal Employment Law on Black Employment,” Journal of Economic Perspectives 4, no. 4 (1990): 47–63. 

12. Examples include: Leonard Carlson and Caroline Swartz, “The Earnings of Women and Ethnic Minorities, 1959–1979,” Industrial & Labor Relations Review 41, no. 4 (1988): 530–46; James S. Cunningham and Nadja Zalokar, “The Economic Progress of Black Women, 1940–1980: Occupational Distribution and Relative Wages,” Industrial & Labor Relations Review 45, no. 3 (1992): 540–55; and Nadja Zalokar, The Economic Status of Black Women: An Exploratory Investigation. U.S. Commission on Civil Rights, 1990.

13. Jonathan S. Leonard, “The Impact of Affirmative Action Regulation and Equal Employment Law on Black Employment,” Journal of Economic Perspectives 4, no. 4 (1990): 47–63. 

14. Examples include: Donald Tomaskovic-Devy, Melvin Thomas, and Kecia Johnson, “Race and the Accumulation of Human Capital Across the Career: A Theoretical Model and Fixed-Effects Application,” American Journal of Sociology 111, no. 1 (2005): 58–89; and Valerie Wilson and William M. Rodgers III, Black-White Wage Gaps Expand with Rising Wage Inequality, Economic Policy Institute, September 2016. 

15. Jenny R. Yang and Jane Liu, Strengthening Accountability for Discrimination: Confronting Fundamental Power Imbalances in the Employment Relationship, Economic Policy Institute, January 2021. 

16. Ibid.

17. See endnote 1.

18. Chang-Tai Hsieh, Erik Hurst, Charles I. Jones and Peter J. Klenow. “The Allocation of Talent and U.S. Economic Growth”, Econometrica, Vol. 87, No. 5 (September 2019), 1439-1474.

19. Adewale A. Maye and Valerie Wilson, Trump is Making it Easier for Employers to Discriminate. This Stifles Equity and Hurts Economic Growth. Economic Policy Institute, May 2025.

Key takeaways:

• The CROWN Act is legislation that protects students, workers, and housing applicants from race-based hair discrimination.
• 30 states have enacted some version of the CROWN Act, building momentum for a federal version to pass in Congress.
• Expansions of civil rights laws like the CROWN Act are more urgent than ever given Trump administration efforts to weaken nondiscrimination protections.

In an era of Trump administration attacks on nondiscrimination protections and diversity, equity, and inclusion (DEI) initiatives, workers and students need the guardrails included in the CROWN Act more than ever.

The CROWN Act stands for Creating a Respectful and Open World for Natural Hair. It expands existing civil rights law to prohibit race-based hair discrimination in schools, housing, and workplaces. Far from being solely focused on aesthetics, the CROWN Act protects against implicit bias and policing of Black and brown bodies. It codifies hair discrimination as racism and prohibits employers, public schools, and housing agencies from imposing whiteness as the uniform for success.

The CROWN Act is now law in 30 states

Pennsylvania and Rhode Island became the most recent states to pass the law in 2025, joining a growing list of states that have passed some form of the CROWN Act. Similar to the limited protections in Kentucky (which only provides public service and employee protections), Missouri also recently passed a limited version of the law that only applies to educational institutions—not workplaces or housing.

Figure A

Since the start of the second Trump administration, five states (Florida, Mississippi, Ohio, North Carolina, and South Carolina) have introduced at least one version of the CROWN Act.

Expanding CROWN Act legislation at the local level can be a significant incremental step toward expanding protections more broadly. In at least three of the states that introduced legislation, local CROWN laws have been adopted in cities including Charlotte, North Carolina, Columbus, Ohio, and Miami Beach, Florida. Such local policies have proven helpful in laying groundwork for passage of state laws elsewhere; for example, localities in Pennsylvania and Missouri passed CROWN Act laws years prior to these passing at the state level.

It’s time to pass the CROWN Act in Congress

Representative Watson Coleman (D-NJ) and Senator Cory Booker (D-NJ) introduced a federal version of the CROWN Act in the House and Senate last February. Neither bill has received a vote. With 60% of states already having passed the CROWN Act, the policy clearly has enough popular support to pass both chambers and become law.

A federal CROWN Act would provide consistent nationwide protection against hair discrimination for workers—especially Black women workers who have larger pay disparities and who are intersectionally impacted by a history of racist laws. Over 38.7% of Black women workers live in states where they are vulnerable to hair-based discrimination, based on the most recent 2024 data. That’s a slight improvement from the 44% of Black women workers who lacked protections in 2023, thanks to six more states—Kentucky, Missouri, New Hampshire, Pennsylvania, Rhode Island, and Vermont—recently passing some version of the CROWN Act.

Table 1

Although some states did not have large enough populations of Black women to be tracked in the data presented in Table 1, Black students and workers in states with smaller Black populations remain susceptible to discrimination. In South Dakota, for example, a student was told to cut their locks or leave school. Black students have shared similar stories in states across the country with varying Black population density.

Expansion of the CROWN Act must be coupled with strong enforcement

In an anti-DEI political climate, preventing hair-based discrimination must be coupled with addressing a growing crisis in federal and state nondiscrimination enforcement systems. Current threats to the Equal Employment Opportunity Commission’s (EEOC) enforcement mission are eroding protections for Black and brown workers. The EEOC was established by the Civil Rights Act of 1964 (the same law that the CROWN Act would expand) and was designed to be an independent federal agency to protect workers and promote fairness and equity in employment. The EEOC’s role in reducing discrimination has helped to boost average income by $493 to $1,233 per person since 1960. Historically, the EEOC has been a key source of protection for Black and brown people and women: A third of all EEOC charges were related to race (29,338) or sex (26,941) last year.

Figure B

Last year, the Trump-appointed chair of the EEOC hijacked the agency’s mission by actively soliciting complaints from white male workers and encouraging “DEI-related discrimination” claims of “reverse racism.” In addition to assigning a new chair, the Trump administration has weakened the EEOC by removing the ability to collect full pay data, limiting gender data collection, and removing commissioners—preventing a quorum and disrupting proceedings.

The Civil Rights Act itself and the protections that the EEOC was created to enforce are at risk. And some states are following the Trump administration’s lead by weakening state-level civil rights laws and enforcement systems. For example, in 2025, Iowa became the first state in history to strip nondiscrimination protection from a protected class when it removed gender identity from its state Civil Rights Act. In response, many cities and counties expanded their local civil rights ordinances to ensure protections against discrimination based on gender identity, but in 2026 the state went a step further and banned local governments from protecting any class not explicitly listed in state law. These recent legislative changes explicitly targeted trans people for discrimination, but will also have the broader effect of preempting local governments from adopting any expanded civil rights protections in the future, including local versions of the CROWN Act.

In the meantime, discrimination has not stopped and continues to have a measurable impact on Black, brown, and women workers—especially related to opportunities for securing a job and workplace advancement. New research finds that 59% of white adults hold anti-Black prejudice, contributing to a greater likelihood that Black applicants are rejected from jobs compared with their white counterparts. Women are paid 18.6% less than men. The disparity increases when considering race: Black women are paid 68.3% and Hispanic women are paid 64.5% of white men’s pay.

It is imperative to both expand protections like the CROWN Act at the local, state, and federal levels and strengthen state civil rights enforcement, while working toward eventual restoration of the EEOC’s capacity to carry out its mission to protect against discrimination in the workplace.

The latest SHED survey also shows that the harm caused by the administration’s economic chaos has not affected all people equally. Structural inequities embedded in the U.S. economy and labor market have historically left communities of color disproportionately vulnerable to economic insecurity and poverty, and the Federal Reserve’s survey shows that this trend is continuing. While the overall financial well-being of most adults held steady in 2025, the financial well-being of Black adults declined. These individuals were also more likely to experience layoffs, leaving a higher share of Black adults and their families with increased fear of finding or keeping a job in 2025. The added employment uncertainty of Black adults also left them significantly more likely to report major concerns about making ends meet. The survey also shows that education largely failed to protect these individuals from the experience of increased economic fragility.

Black adults find themselves in the worst financial position in nearly a decade

In 2025, Black adults were most likely to report a decline in their financial standing. The share of Black adults “doing okay” or “living comfortably” declined by almost 5 percentage points last year to 60% (see Figure A). This is the lowest figure the Survey of Household Economic and Decisionmaking survey has recorded since 2015. The 2025 figure also reflects a steep decline from the high of 2023, when nearly 68% of Black adults answered questions about their financial well-being positively. We find that the bulk of the decline last year took place among the individuals who reported “living comfortably,” as this share declined from 23% in 2024 to 19.0%.

Figure A

Higher education largely failed to protect Black individuals from added financial insecurity under the Trump-Vance economy. While nearly all Black adults with varying levels of education experienced a deterioration of their financial position last year, the situation of adults with a college education worsened the most (see Figure B). The share of these individuals doing okay or living comfortably, for example, declined by nearly 7 percentage points last year.

Figure B

Black adults were more likely to experience a sharp increase in layoffs last year

By summer 2025, job growth had slowed considerably, and Black workers were among the first to experience this slowdown with a rising rate of unemployment. The uneven impact of these debilitating forces last year comes across clearly in the Federal Reserve survey. The share of Black adults who reported experiencing a job loss increased by about 3 percentage points between 2024 and 2025 (see Figure C). This reflects the largest increase among all racial and ethnic groups. In fact, Black adults were more than twice as likely as their white, non-Hispanic peers to report layoffs last year. This reality aligns with the broader labor market position of Black workers, who experienced a steeper rise in their unemployment rate in 2025 and who remained about twice as likely as their white peers to be unemployed. 

Figure C

As the pace of job growth slowed and the unemployment rate rose in the first year of the Trump-Vance administration, people’s concern with finding or keeping a job increased. But this increased employment vulnerability and insecurity fell most heavily on Black individuals and their families (see Figure D). More than half of Black adults said that finding or keeping a job was either a minor or major concern for them or their families last year. This figure increased by nearly 10 percentage points between 2024 and 2025. In fact, Black adults of all education levels reported increased concerns about finding or keeping a job last year. 

Figure D

Black adults and their families have grown increasingly more concerned about their economic security

The added employment vulnerability, combined with the impact of the ongoing affordability crisis, has also left more Black individuals and their families worried about their ability to make ends meet. More than 3 out of 4 (77.5%) Black adults reported that making ends meet was at least a minor concern for them and their families last year (see Figure E). This figure increased by about 8 percentage points between 2024 and 2025, leaving Black adults of all education levels more economically vulnerable last year. In contrast, the share of white, non-Hispanic adults who reported similar concerns declined marginally during the same period.

Figure E

We cannot address the affordability crisis without dealing with its root causes

The Federal Reserve survey points to the relationship between employment, economic security, and well-being. The uneven impact of the weaker job market last year resulted in increased employment and economic uncertainty for Black adults and their families. The survey findings are a reminder that ongoing discussions about the affordability crisis shouldn’t ignore the role of employment, wages, and income. Affordability remains an outcome of a race between income and prices, and we know that the pace of job and wage growth is a policy choice. While there is no silver bullet, we know that a broad basket of policies is needed, including a higher wage floor, increased union density, and macroeconomic policies that reduce inequality.

In the last two years, Republicans in Tennessee have attempted to push legislation that would violate Plyler to set the stage to challenge the court decision (although neither proposal passed). Last year, the state proposed charging undocumented students tuition for public schools, and this year, Tennessee attempted to pass legislation to track the immigration status of all public school students.

The 1982 ruling of Plyler v. Doe is notable because it stated that the harm of not educating undocumented children would be worse for society than providing a basic education to all children in the U.S. The ruling recognized the huge positive spillovers public education has on the U.S. labor market, public health, and civil society and that leaving immigrant children out of public education would create an “underclass” in U.S. society.

Moreover, if the move to deny public education to children in the U.S. is successful, particularly in pockets of the country where immigrant children are a substantial share of the student population, it will lead to an extraordinarily high cost for the students who remain in public school.

Some school costs are hard to adjust, regardless of the number of students

Across the country, an estimated 17% of school-aged children live with at least one noncitizen adult, according to the Kaiser Family Foundation. If these students were to leave suddenly, schools would be left to educate a fewer number of kids without any time to adjust their fixed costs. For example, when Alabama passed an immigration data collection law, more than 13% of Hispanic schoolchildren withdrew from classes.

At first, it would seem that reducing enrollment would reduce both total revenue and the number of students needing educational services proportionately, which should leave the schools’ ability to provide education unaffected. But schools can’t adjust every educational cost quickly: School bus routes still need to circulate to all stops, even if there is one fewer child in need of transit; buildings need to be heated and cooled, even if classroom size goes down; and guidance counselors and support staff are still required to support the remaining students.

School districts will pay more per pupil if student enrollment declines because of immigration enforcement

Since these fixed costs can’t be adjusted in the short run, when total revenue declines due to families’ fears of deportation, districts are stuck paying more per pupil on costs they can’t adjust. Effectively, native-born students who remain in public schools receive no additional benefit when immigrant students are denied services and rights. Districts instead will be paying more on costs that can’t be adjusted and getting less on the costs that can be adjusted for fewer students.

Calculating the cost under two different scenarios

We call all the costs of downward adjustment that occur when enrollment is reduced the fiscal externality. This means the per-pupil funds each district would require to maintain the same level of spending for remaining public school students due to a rapid decline in enrollment. This cost is entirely borne by state and local education budgets and leaves districts unable to deliver the same level of instruction to the remaining public-school pupils.

For districts with a large share of school-aged children in immigrant families, the costs of losing these students could be substantial. Table 1 shows the top-25 school districts, based on the number of K–12 students that are in immigrant families and the corresponding fiscal externality for two scenarios. In the first scenario, half of these students stop attending public school (referred to as the lower bound in the table). In the second scenario, all of these students stop attending public school (referred to as the upper bound in the table).

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The implications of a reversal of Plyler v. Doe or any type of policy restricting immigrant children’s access to public education would be extreme for these districts. In Houston, Texas, where 62% of students in the school district are Hispanic, we estimate that nearly 63,000 students may live in a household with immigrants and as such, might be vulnerable to dropping out of school due to anti-immigration efforts. The lower bound shows the costs if half of these students stopped showing up. Houston School District would have to reduce services by $1,654 for each remaining (and disproportionately native-born) public school student. This decline translates to a total fiscal externality of $268 million a year, or 11% of the total budget for the school district.

The extraordinarily high cost to native-born students of losing students in immigrant families due to anti-immigrant policies highlights the hypocrisy in the anti-immigrant movement. If all students in immigrant families stopped attending public school tomorrow, not only would those students suffer from the lack of public education, but the quality of public education would be much worse for the remaining students in those same schools. In short, no one wins. When the costs are tallied up, it’s clear that these policies are not about improving education quality for native-born students, but instead are malicious attacks on the institution of public education in the U.S.

Figure A

These increases continue to be crucial for low-wage workers as they contend with the affordability crisis. The average increase in annual wages for a full-time, year-round worker resulting from these minimum-wage hikes ranges from $573 in Oregon to $811 in Alaska. These pay raises directly boost workers’ incomes, giving them a leg-up in the race against rising prices—a straightforward example of how policymakers can often more easily tackle affordability challenges through policy decisions that boost wages, such as setting strong wage floors.

A higher minimum wage has a positive impact on more than just the workers who currently earn the minimum wage; indirectly affected workers will see their pay go up too as employers adjust their wage ladders to the new wage floor. Our analysis of the increases in Alaska, Oregon, and Washington, D.C., accounts for these “spillover” effects and finds:

• Women make up more than half (56.3%) of affected workers.
• The wage increases disproportionately benefit Black and Hispanic workers. Black workers make up 15.3% of affected workers, despite making up 10.4% of the workforce across the three areas. Hispanic workers make up a similar percentage of the workforce (12.4%) but make up more than a fourth (26.0%) of affected workers.
• The vast majority (89.3%) of affected workers are age 20 or older, and more than 3 in 5 workers (62.1%) are 25 or older.
• More than half (52.9%) of the affected workers work full-time.
• The increases will raise wages for those who need it the most. Half (50.5%) of affected workers belong to households whose incomes are less than 200% of the poverty line.
• More than 1 in 5 (23.6%) of affected workers are parents.

Table 1

State and local policymakers should combat cost-of-living challenges with minimum wages

Because costs of living can vary significantly within a state, local policymakers should establish strong wage floors if the state minimum wage is inadequate for their area. In June, city councilors in Albuquerque, New Mexico, took an important step in that direction, passing a minimum-wage increase to $15 an hour by 2029. Whereas the current state minimum in New Mexico is $12 an hour, EPI’s Family Budget Calculator shows that a living wage for a single adult working full-time in Albuquerque is $17.56 an hour.1 The proactive step taken by local elected officials will provide significantly more economic security for low-wage workers in the city.

This summer, the minimum wage will increase in localities in California, Illinois, and Maryland (Table 2) due to “indexing”—automatic annual adjustments written into the minimum-wage law that require the wage floor be adjusted for price increases each year. Without indexing, the minimum wage is worth less and less every year as prices rise. With time, this can dramatically erode the value of the minimum wage. For example, the federal minimum wage of $7.25 an hour—which has not increased since 2009—has now lost 30% of its purchasing power.

Table 2

Indexing to inflation is a commonsense policy enacted in dozens of cities and states across the country, but it is not the strongest way to protect the value of the minimum wage. Adjusting for price increases mostly protects the real value of a low-wage worker’s paycheck (although low-wage workers are more vulnerable to inflation than top-of-the-line inflation measures indicate). However, in a well-functioning economy, wages for most workers—especially higher wage workers—will grow faster than inflation. If the minimum wage only rises at the rate of price growth, then over time, this can increase inequality between low-wage workers and everyone else.

One way to address this issue and ensure that low-wage workers do not fall further away from the middle class is to index the minimum wage to median wage growth. EPI’s latest vision for a federal minimum wage explicitly targets a wage floor that rises to two-thirds of the median wage and remains indexed there thereafter. This policy both creates a high floor that provides significantly higher wages for workers across the country and protects the minimum wage’s value against price increases and increases in wage inequality over time.

Oklahoma fails to pass minimum-wage ballot measure

In June, a minority of eligible Oklahoma voters rejected a ballot initiative (State Question 832) that would have increased the state’s minimum wage to $15 an hour by 2029. The initiative’s failure is a costly missed opportunity to increase wages for Oklahoma workers. More than 1 in 5 workers in the state earn less than $15 an hour, and if passed, the ballot initiative would have provided more than $783 million in increased earnings for low-wage workers.

During a time when cost of living and inflation are some of the most important concerns for voters, Oklahomans might have worried that increasing the minimum wage would have hurt affordability in the state. In fact, the opposite is true. Although raising the minimum wage can lead some affected businesses to increase prices, the resulting price increases are extremely modest—far smaller than the increase in pay that would go to low-wage workers. Even some of the most ambitious wage floor policies, such as California’s $20 fast food minimum wage, only increased fast-food prices 2.1% (around eight cents for a $4 item). A 10% increase in the minimum wage is associated with a 0.14 percentage point increase in CPI increase. In contrast, a 10% minimum-wage increase boosts income at the 10th percentile by around 3.6%, an order of magnitude greater. The average full-time, year-round Oklahoman worker affected by SQ 832 would have gained $2,322 in annual wages if voters had approved the initiative.

It is also important to highlight SQ 832’s winding path to the ballot. Ballot initiatives have historically been an important mechanism for passing minimum-wage increases in states with conservative-dominated legislatures like Florida, Missouri, and Nebraska. While Oklahoma is one of only three states in the South that has a ballot initiative process, conservative politicians have been increasingly curtailing it.

The Oklahoma minimum-wage ballot initiative is a prime example of this. Advocates originally began collecting signatures for SQ 832 in the lead-up to the November 2024 general election. Despite collecting nearly twice the necessary signatures in enough time to qualify for the ballot, advocates were thwarted when Governor Kevin Stitt delayed the State Question until the June 2026 gubernatorial primary election, a low turnout election in contrast to a general election with presidential candidates on the ballot. Voter turnout in the 2026 primary election was 26%, around half of what it was in the 2024 election.

In response to the emergence of SQ 832, the Oklahoma legislature also passed restrictions on the signature-gathering process, limiting the number of signatures that can be gathered from populous areas like Tulsa and Oklahoma City. These restrictions will make it more costly and logistically challenging to pass a future minimum-wage increase in Oklahoma. With such low voter turnout and marked interference in the ballot initiative process, it is difficult to say that SQ 832’s failure reflects a lack of popular support for minimum-wage increases in Oklahoma. Regardless of the cause, without a future minimum-wage increase, the issue of low pay in Oklahoma is only going to grow.

When policymakers like those in Oklahoma fail to adequately set the wage floor, it suppresses worker pay, not just for the lowest-paid workers, but for low-wage workers in general. Workers need a raise to help them overcome the affordability crisis, and the minimum wage is an evidence-backed tool under policymakers’ control to help them do that.

1. Assuming 81% of income comes from wages.

Key takeaways:

• Misclassification of workers as independent contractors is a pervasive and widespread problem. AAPI workers are overrepresented in three of the 11 commonly misclassified occupations: manicurists and pedicurists, home health aides, and personal care aides. Vietnamese, Bangladeshi, Filipino, Samoan, and other Pacific Islander workers are overrepresented within these occupations.
• Groups with lower median hourly wages also have larger shares of their working populations in the 11 commonly misclassified occupations.
• Federal protections against misclassification are limited and currently under attack by the Trump administration. The state and local landscape for curbing misclassification is varied, which leaves some workers less protected than others.

In March, EPI published updated research highlighting the cost to workers of being misclassified as an independent contractor for 11 commonly misclassified occupations. Asian American and Pacific Islander (AAPI) workers were overrepresented in three of those occupations—manicurists and pedicurists, home health aides, and personal care aides—relative to their share of the overall workforce.

Most federal, state, and local labor laws apply only to employees and not to independent contractors, so misclassification strips workers of key protections such as minimum wage laws or qualifying for employer-provided health insurance and retirement benefits. Additionally, both misclassified workers and social insurance funds lose out on income: the report conservatively estimates that for the three jobs in which AAPI workers are overrepresented, misclassification costs workers at least $7,000 annually and costs social insurance programs $600 to $800 per worker each year.

With the understanding that the umbrella term “AAPI” encompasses an immensely diverse population both in ethnic origin but also in economic outcomes, this piece goes beyond the narrow view that all AAPI workers are high-wage earners. Below, we provide more detail on which groups of AAPI workers are most likely to be employed in lower-wage commonly misclassified occupations.

Disaggregated data shed light on particular AAPI communities that may be vulnerable to misclassification

Across all occupations, AAPI workers comprise approximately 8% of the total workforce. For three of the 11 occupations highlighted in the report—manicurists and pedicurists, home health aides, and personal care aides—AAPI workers make up 67%, 13%, and 10% of employment, respectively, according to Current Population Survey (CPS) data.

Table 1 provides a detailed breakdown of the composition of the AAPI workforce for the three occupations in which AAPI workers are overrepresented. Here, we use the American Community Survey (ACS) as it offers detailed race definitions which the CPS does not offer due to sample size restrictions.

Asian Indian and Chinese populations combined make up over 40% of the working-age AAPI population, thus their relatively large shares of the AAPI workforce in these occupations are not surprising. However, several groups are disproportionately represented across these occupations compared with their share of the overall AAPI workforce.

For example, Bangladeshi workers make up 5.1% of AAPI workers employed as home health aides while only constituting 1.1% of the total AAPI workforce. Chinese workers represent almost half (47.7%) of AAPI home health aides while representing just over one-fifth of the overall AAPI workforce (20.9%). AAPI employment among manicurists and pedicurists is largely held by those of Vietnamese origin (71.4%).

Finally, a majority of AAPI personal care aides are either Filipino (32.8%) or Chinese (20.8%). Filipino workers, however, are overrepresented by twice their share of the overall workforce. While Samoans and other Pacific Islanders comprised a much smaller share of personal care aide employment, they are also overrepresented in this occupation by more than twice their share of the overall workforce.

Table 1

Figure A provides a more comprehensive picture of the share of each detailed group employed across all 11 commonly misclassified occupations, revealing that smaller communities—often overlooked because of their size relative to the aggregate AAPI workforce—may be among the most vulnerable to misclassification. Workers belonging to seven of those groups are more likely than the average U.S. worker to be employed in one of those occupations. Almost 20% of Vietnamese workers are employed in one of those occupations, with over half concentrated as manicurists and pedicurists.

Samoan, Hawaiian, and other Pacific Islanders have the next highest shares working in the 11 occupations, making up 15% or more of their total working-age population. These groups also earn lower median hourly wages than the national median and the aggregate AAPI median hourly wage. Their disproportionate representation in commonly misclassified occupations further exposes these workers to wage suppression due to misclassification.

Misclassification enforcement varies by state—meaning different AAPI populations can be disproportionately impacted

Federal protections from misclassification are limited and are currently under attack by the Trump administration, which has proposed a rule to weaken standards to determine worker classification under the Fair Labor Standards Act, the Family and Medical Leave Act, and the Migrant and Seasonal Agricultural Protection Act. The proposed rule narrows the definition of who is a covered employee under these statutes, encouraging employer schemes to reclassify their employees as independent contractors to evade those obligations.

Broadly, the Trump administration has been actively dismantling long-standing federal worker protections, leaving states to bear the responsibility of ensuring workers are given rights and protections and that they can exercise them. For most states, labor and employment protections only apply to workers classified as employees, meaning workers misclassified as independent contractors are denied their legal rights and protections.

EPI’s 2026 misclassification report outlines state and federal policy recommendations that ensure proper enforcement mechanisms to curb misclassification. One of the recommendations includes implementing the ABC test. Unlike the six-part “economic reality” test or the “common law” test, the ABC test presumes that a worker is an employee unless they can demonstrate they are an independent contractor based on three criteria. Placing the onus on the employer to determine the employment status of a worker provides protections against misclassification and extends proper protections to workers. Many states have adopted the ABC test for unemployment insurance programs and, to a lesser extent, for wage and hour orders and other employment applications.

As shown in Figure B, The AAPI population is highly concentrated across a handful of states. Almost half of the prime-age working Asian population is concentrated in California, New York, and Texas, and a majority of the Pacific Islander population resides in California, Hawaii, and Washington. Overall, 21 states have significant numbers of AAPI residents, and some are home to large shares of specific AAPI communities. For example, the Hmong community in Minnesota and the Burmese community in Indiana are concentrated in states that have smaller total AAPI populations.

The current landscape for state policy protections against misclassification is quite varied. For example, among the states with the largest AAPI populations, California is the only state to adopt the ABC test for both unemployment insurance and employment law, although certain occupations are exempt from the test—including app-based drivers. California also institutes penalties for misclassifying a worker, which can include restitution payments and, if the misclassification was willful, a penalty between $5,000 to $25,000 per violation.

Texas, on the other hand, has significantly less state enforcement. Apart from using the common law test for its unemployment insurance program and providing a definition of an independent contractor for workers’ compensation, Texas mainly relies on federal law for classifying workers as employees. In the last 15 years, Texas lawmakers have introduced several bills that would create penalties for misclassifying workers in the construction industry, but all have stalled or failed.

Figure B

Comprehensive protections are needed to protect workers from misclassification

AAPI workers are facing multi-pronged attacks from the Trump administration through the degradation of federal protections for workers, immigration, and equity. Occupational segregation and other labor market disparities lead women, people of color, and immigrants to be disproportionately represented in occupations that are commonly misclassified. These factors—in addition to historical and current geopolitical relations that shape the flow of labor to the U.S., immigration and citizenship status, and English language proficiency—can contribute to the concentration of AAPI workers in these occupations. Disaggregated data further identify which specific AAPI communities are overrepresented, revealing that smaller, less economically secure groups are often most exposed to the costs of misclassification. Strong policies at the federal, state, and local levels are needed to combat misclassification and to ensure workers can exercise their rights.

Our decisions about whom and how to tax are decisions about which community needs we have the capacity to address and at what scale. Progressive taxes like personal, investment, and corporate income taxes generate more revenue from those who have the greatest ability to pay, and for whom the cost of losing the next dollar is small, relative to the last dollar of a family struggling to make rent and afford groceries. On the other hand, regressive revenue strategies like non-strategic tariffs, fees and fines, and an overreliance on sales taxes, especially when combined with cuts to social programs, heighten the sense that the system is unfair. Where progressive revenue strategies can bind a community together in mutual support and expand capacity to meet needs through good governance, regressive strategies erode people’s trust in the public sector.

H.R. 1 presents a vision of public finance that is unsustainable and erodes trust in government

Much of the federal tax code is in fact progressively structured, but for decades conservatives have weakened and attacked that progressivity. H.R. 1 (which the White House has referred to as the “One Big Beautiful Bill Act” or “OBBBA”) is the latest Republican-led effort toward breaking down trust in the public sector and social contract. H.R. 1 provides a suite of tax breaks to households across the income distribution; however, the wealthiest households and corporations see a far bigger tax cut from the package than the typical household does. In service to these tax breaks, the bill introduces devastating cuts to Medicaid, SNAP, and critical government agencies designed to help workers and their families thrive. Despite their size and the pain they will cause, these drastic cuts in the federal government’s capacity to serve and support working families are not enough to cover the costs of the corporate tax breaks; the Tax Policy Center estimates that H.R. 1 could increase the federal deficit by between $3.7 trillion and $5.1 trillion by 2034.

But unlike the federal government, states and localities cannot run budget deficits; their budgets must be balanced yearly. When major federal cuts happen, states and localities that rely on federal dollars to maintain critical services are forced to curtail and eliminate services, dive into emergency savings where they exist, or else shift to revenue generation strategies that often fall disproportionately on Black, brown, and poor households. The combination of directly hampering public services working people rely on while shifting more of the burden of raising revenue toward Black, brown, and poor workers and their families weakens worker power and exacerbates racial disparities.

H.R. 1 combines a shift toward regressive revenue strategies with massive tax breaks to corporations and the wealthiest households, in service to the Trump administration’s overarching goal: reasserting white, wealthy, and corporate privilege through tax cuts, deregulation, and the defunding of public institutions.

Regressive revenue strategies: Taking from the poor to give the rich even more breaks

The Trump administration has floated using tariffs as a replacement (either in full or part) for the federal income tax. This is not a new Republican strategy: Tariffs are a kind of consumption tax (on imported goods, along with the intermediate products businesses need to create goods and provide services domestically), and Republican-led state governments tend to rely more on consumption taxes1 (like sales taxes) and less on income taxes to increase revenue. Because poorer households spend a larger share of their income purchasing goods and services than the rich do, consumption taxes are inherently more regressive. The current federal income tax is progressively structured, in spite of the ways conservatives have attempted to weaken that progressivity over time. While tariffs can be a sensible part of a larger industrial policy strategy, governments place too large a burden on low- and moderate-income households when they try to use consumption taxes as a primary source of revenue. 

States and localities may turn to fines and fees to raise revenues in the absence of adequate federal support. These penalties are a poor substitute for progressive taxes. Fines and fees historically have only been able to cover a small fraction of state and local budget costs. And this is baked into the design: If the point of a fine or fee is to deter behavior, the best-case scenario (ending the behavior) would result in no revenue.

Even so, fines and fees cause significant economic pain for working-class families in the Black communities that are most affected by them. On an ethical level, a modern idiom applies: “If the penalty for a crime is a fine, that crime only exists for the poor.” The criminal justice system can trap poor folks in a cruel cycle of penalization for being unable to pay traffic tickets, court fees, and even their own surveillance through ankle monitors. Fines and fees increase the economic burden on those with the least ability to pay, all for a low return, making them a poor substitute for broad, progressive taxes.

Faux-progressive revenue strategies are ineffective and distract workers, their families, and policymakers from the need for real change

Ineffective tax gimmicks like temporary deductions on overtime and tipped income distract from the need for real reform around worker pay and scheduling. The point of requiring businesses to pay time-and-a-half for overtime is to discourage pushing workers to work beyond what we have collectively decided is a full and reasonable period of labor. Tipping is an outdated practice with racist roots, designed to shift the cost of maintaining a workforce onto consumers, rather than having employers properly compensate employees. Instead of cynically gesturing toward affordability through encouraging bad business practices, we should empower workers to fight for better wages and consistent scheduling.

Conservatives may also try to balance budgets by allowing progressive tax expenditures to expire (e.g., the recent expiration of the ACA premium tax credits or the expiration of the expanded child tax credits passed as pandemic relief). Temporary tax breaks themselves are not the most effective means of addressing structural economic issues; if health care or health insurance is persistently inaccessible to wide swaths of the population, we should seek to remedy that by making access universal—or, at the very least, making the credits that allowed greater access in the first place permanent. Allowing tax breaks implemented to address structural inequities to expire without an alternative solution to the problem being addressed is negligence. There are ways to balance budgets that do not involve reversing hard-won progress toward equity.

Progressive ways to generate revenue: Worker-centered tax policies can reduce inequality and expand the tax base

There are better ways of raising revenue that will support workers and their families, rebuild public trust in government, and get us the public goods and services we want and need. Since most Americans earn their living through selling their labor, it makes sense to keep some progressive tax on income to ensure people remain invested in the social contract. But with so much wealth and income concentrated amongst a few individuals, a necessary step is shifting more of the tax burden toward extremely high earners, wealth, and investment income. This will generate more revenue to improve public services and infrastructure, while tamping down on inequality. Adding tax brackets for the highest earners, adopting a legitimate tax on wealth holdings, and taxing the income made from investments at a rate closer to that of income from wages and salaries progressively raise revenues without increasing the burden on most U.S. households.

Proper enforcement of the current tax code would go a long way toward improving both our ability to raise funds and the public’s trust in public finance. The tax code is rife with opportunities for wealthy individuals and corporations to evade paying their fair share of taxes, allowing them to skirt holding up their end of the social contract. The IRS is also critically underfunded and recovering from recent staff reductions from the Trump administration. With enough resources to enforce existing tax law effectively, the IRS could go after the largest tax evaders and see returns that matter, as opposed to disproportionately targeting Black households without the funds to instigate a drawn-out legal battle over an audit.

Table 1

We need a tax code that supports states and localities and promotes full economic participation, not temporary tax gimmicks and handouts to the wealthiest

Taxpayers (literally) cannot afford to accept the conservative propaganda that all taxation is a burden on households. Taxes are one way of binding a democratic community together and allowing us to share in the costs of creating collective prosperity and community. Especially at the state and local levels, tax revenues are essential to providing the services people need to thrive. When federal funding gets pulled back and states and localities turn to regressive revenue strategies, it is working-class families who pay the price.

If we are going to rebuild a sense of trust in the social contract, we need to structure the tax code such that it becomes more progressive, tapping into a greater portion of the massive amounts of wealth and income that have pooled at the top. We can use that revenue to fund programs and new infrastructure that allow more people to fully participate in the economy:

• improved funding for public schooling, increasing teacher pay and quality of education
• a fully funded federal food assistance program, and/or adequate funding to states to support their own cash-assistance programs more comprehensive than Temporary Assistance for Needy Families (TANF)
• expanded access to and adequacy of Medicaid, or Medicare for All

Each of these initiatives could improve affordability and remove the need for state and local governments to pursue revenue regressive strategies that do more harm than good (like fines and fees). We won’t solve every structural inequality and eliminate all disparities through reforming the tax code; but building the resources and will to collect taxes in a progressive way are steps toward a fairer economy and a government that earns the public’s trust.

1. Consumption taxes have some potential uses. Carbon taxes, for example, tax the consumption of goods whose production intensively uses greenhouse gas-emitting inputs; if consumers look to avoid these goods by switching to others whose production involves fewer greenhouse gas emissions, we achieve an important social good.

Key takeaways:

• Black unemployment rose and employment fell in Q1 2026, reflecting a deterioration in labor market conditions. In the first quarter of 2026, the Black unemployment rate (7.6%) was 1.2 percentage points higher than in the first three months of the second Trump administration.
• Black men’s employment-population (EPOP) ratio decreased by 1.7 percentage points (from 60.5% to 58.8%) since the first quarter of 2025, with noncollege graduates driving this decline.
• Black women’s EPOP ratio was the same in Q1 2026 as in Q1 2025 (56.4%), with gains among noncollege graduates offsetting losses among college graduates.

The rising Black unemployment rate and big employment losses among Black women made major news headlines in 2025. In a February 2026 analysis, I examined the nature of those losses, noting the large impact on Black women who were college graduates and public-sector workers. With so much of the Trump policy-induced 2025 labor market decline appearing to land first on Black workers who typically have relatively secure employment, the longer-term significance of those losses is of continuing interest. This post provides an update for the first quarter of 2026, examining changes in the overall Black unemployment rate and gender-specific employment trends for Black women and men relative to the first quarter of 2025. For consistency with the prior analysis, I apply the same mutually exclusive race and ethnicity categories used in EPI’s State of Working America Data Library and include all people age 16 or older when examining outcomes by gender. While these estimates differ slightly from those reported by the Bureau of Labor Statistics (BLS), they lead to similar conclusions.

In the first quarter of 2026, the Black unemployment rate (7.6%) was 1.2 percentage points higher than in the first three months of the second Trump administration. While a rise in the unemployment rate can sometimes be for “good” reasons—workers getting drawn into the labor force because of strengthening job opportunities—that was not the case here: the rise in the Black unemployment rate reflected a decline in employment. The Black employment-population ratio (EPOP)—the share of working-age people who are employed—declined 0.8 percentage points over the same period, from 58.3% in Q1 2025 to 57.5% in Q1 2026 (see Figure A).

Figure A

Looking more closely at changes in employment for Black women and men separately, Black women’s first quarter EPOP was the same in 2026 as in 2025 (56.4%), while employment among Black men was 1.7 percentage points lower (from 60.5% to 58.8%). BLS published estimates by race—limited to the sample of people age 20 or older and not exclusive of ethnicity—show a similar decline for Black men (-1.5 percentage points), but a 0.4 percentage point increase for Black women.

Figure B shows that among Black women, Q1 2026 employment was lower than Q1 2025 for college graduates but higher for noncollege graduates, resulting in essentially offsetting effects. The opposite was true among Black men, for whom the decline in employment was driven by lower employment among noncollege graduates and higher employment for college graduates.

Figure B

These first quarter 2026 estimates incorporate annual population adjustments applied to Current Population Survey (CPS) data each January to reflect updated population estimates from the U.S. Census Bureau. Since the previous year’s data are not adjusted, monthly data across the two years are not strictly comparable. This year, shifts in the demographic composition of the population also resulted in larger than usual discontinuities in labor force measures by race, ethnicity, and gender between December 2025 and January 2026—which is why this analysis is focused on a comparison between the first quarters of 2025 and 2026, when the population controls are the most up to date.

Based on this analysis, we can conclude that overall, labor market conditions for Black workers were not better in the first quarter of 2026 compared with the early months of the Trump administration. Black men’s employment is lower than what was reported in the first quarter of 2025, and while Black women’s employment is unchanged overall, employment among college-educated Black women is lower than first quarter 2025 estimates.