SHRM Urges EEOC to Prioritize Practical Guidance in Strategic Plan

SHRM has submitted comments supporting the Equal Employment Opportunity Commission’s (EEOC) proposed Strategic Plan for fiscal years 2026 - 2030 while encouraging the agency to place greater emphasis on practical compliance resources, technical assistance, and collaboration with employers. The comments were filed during the EEOC’s public comment period following the commission’s release of the draft plan on July 1. 

Unlike the EEOC’s National Enforcement Plan, which establishes the agency’s principal enforcement priorities, the Strategic Plan functions as its long-term management blueprint. The document outlines the commission’s mission, strategic goals, and performance measures that will guide agency operations, resource allocation, and organizational priorities through 2030. The draft plan focuses on strengthening enforcement, expanding outreach and education, improving intake services, enhancing organizational excellence, and increasing operational efficiency. 

In its comments, SHRM expressed support for the EEOC’s overarching mission of preventing and remedying unlawful employment discrimination. The association argued, however, that prevention is most effective when employers clearly understand their legal obligations before workplace issues escalate.

“While enforcement remains a critical function of the EEOC, prevention is most effective when employers and employees understand their obligations, rights, and responsibilities before workplace concerns develop into unlawful conduct,” SHRM wrote.

To achieve that goal, SHRM urged the commission to develop more plain-language guidance, real-world examples, and technical assistance that translate legal requirements into practical workplace applications. The association said employers would benefit from additional resources distinguishing unlawful discrimination from ordinary workplace conflicts, explaining reasonable accommodation obligations, addressing emerging issues such as social media and out-of-office conduct, and providing examples of effective compliance and prevention programs.

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SHRM also encouraged the EEOC to update several key guidance documents. Among its recommendations were issuing revised harassment guidance that incorporates current workplace realities, developing additional resources on AI and other emerging technologies, and pursuing any modernization of the Uniform Guidelines on Employee Selection Procedures through a formal notice-and-comment rulemaking process rather than informal guidance.

SHRM further called for greater cross-agency coordination, encouraging the EEOC to work with agencies such as the National Labor Relations Board and the Department of Labor to clarify areas where federal workplace laws overlap, including the interaction between Title VII of the Civil Rights Act of 1964, the National Labor Relations Act, the Family and Medical Leave Act, the Americans with Disabilities Act, and the Pregnant Workers Fairness Act. 

SHRM concluded that regular engagement with employers, HR professionals, and workplace experts will help ensure the EEOC's final Strategic Plan reflects real-world workplace challenges while promoting compliance and equal employment opportunity.