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EEOC reset: What a new majority and shifting priorities mean for employers

December 2025 employment law letter
Authors: 

Lisa M. Brauner, Whiteford, Taylor & Preston, L.L.P.

The U.S. Equal Employment Opportunity Commission’s (EEOC) posture has shifted, and employers should take note. With the recent confirmation of a second Republican EEOC commissioner, Brittany Panuccio, the EEOC has a quorum on its five-seat panel, with a two-to-one Republican majority. With the quorum restored, the EEOC can alter policy, guidance, strategic plans, and litigation priorities.

What to expect

Early moves by EEOC Acting Chair Andrea Lucas indicate reduced processing of certain transgender-related charges (only processing complaints involving “hiring, discharge or promotion”), moving to dismiss gender identity cases the agency had been pursuing, and a deprioritization of claims based on a disparate impact theory of liability.

With the EEOC now able to vote on its direction and initiatives, employers should expect to see:

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