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  3. Timeline: Trump’s First 100 Days and the HR Impact 
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Timeline: Trump’s First 100 Days and the HR Impact 

April 25, 2025 | Allen Smith, J.D.

The White House.

From executive orders to administration memos to court decisions, the first 100 days of President Donald Trump’s second term have seen a whirlwind of activity affecting the HR profession. Here’s a rundown of some major actions impacting both private companies and the federal government — and why they matter to HR. 

Jan. 20: “Ending Radical and Wasteful Government DEI Programs and Preferencing” executive order (EO 14151) 

What Happened: This order called for the termination of “all discriminatory programs” — specifically referencing diversity, equity, and inclusion (DEI) — in the federal government.   

What It Means for HR: By calling for the termination of DEI programs labeled as discriminatory, EO 14151 may affect federal hiring practices, employee training initiatives, and equitable workplace development strategies. In response, SHRM developed the Belonging Enhanced by Access through Merit (BEAM) Framework to help organizations comply with the orders by using merit-based hiring to build a more inclusive workforce. 

Toolkit: Implementing SHRM’s BEAM Framework for Inclusion

Jan. 20: “Defending Women from Gender Ideology Extremism and Restoring Biological Truth to the Federal Government” (EO 14168)  

What Happened: The EO defined sex in binary terms (male and female). In response, the U.S. Equal Employment Opportunity Commission (EEOC) said it’s “returning to its mission of protecting women from sexual harassment and sex-based discrimination” and rolling back the “gender identity agenda.”  

What It Means for HR: The implementation of EO 14168 and the EEOC’s response could change how some HR professionals approach EEO-1 reporting — mandatory annual data collection required by the EEOC — particularly in the identification of employees by sex.  

FAQ: Understanding Workplace Gender Policies Under New Executive Orders

Jan. 21: “Ending Illegal Discrimination and Restoring Merit-Based Opportunity” (EO 14173) 

What Happened: This order rescinded EO 11246’s affirmative action requirements based on race and sex for federal contractors. It also encouraged the private sector to “end illegal discrimination and preferences.”  

What It Means for HR: HR must focus on merit-based employment practices  and remain vigilant in identifying and eliminating all illegal discrimination, including so-called reverse discrimination. 

How-To Guide: How to Build Effective, Legally Compliant Inclusion & Diversity Programs 

Jan. 23: “Removing Barriers to American Leadership in Artificial Intelligence” (EO 14179)  

What Happened: After rescinding EO 14110, “Safe, Secure, and Trustworthy Development and Use of Artificial Intelligence,” which was signed by then-President Joe Biden in October 2023, Trump issued this EO requiring a review of “certain existing AI policies and directives that act as barriers to American AI innovation.” The EEOC and U.S. Department of Labor’s previous guidance on AI will be reviewed to ensure alignment with this EO.  

What It Means for HR: This could mean less red tape for HR in using AI to work faster and more efficiently. 

Feb. 5: Attorney General Pam Bondi issued a memo regarding the execution of EO 14173 as it relates to private-sector companies. 

What Happened: Bondi said the U.S. Department of Justice (DOJ) would begin evaluating enforcement mechanisms of the DEI EOs against private-sector companies. The memo directed the DOJ’s Civil Rights Division and Office of Legal Policy to jointly submit a report with recommendations for “measures to encourage the private sector to end illegal discrimination and preferences, including policies relating to DEI and DEIA [diversity, equity, inclusion, and accessibility].” However, information about the resulting report has not been made public.  

What It Means for HR: HR professionals in the private sector must prepare for increased scrutiny regarding their organizations’ inclusion and diversity (I&D) initiatives. 

Feb. 19: “Ensuring Lawful Governance and Implementing the President’s ‘Department of Government Efficiency’ Deregulatory Initiative” (EO 14219)  

What Happened: The order directs government agencies to identify rules that it believes unduly burden small businesses and impede private enterprise. A regulatory agenda will then be developed to rescind or modify these regulations.  

What It Means for HR: By aiming to reduce regulatory burdens, the initiative may result in fewer constraints tied to workforce management. 

Feb. 21: A U.S. district court judge preliminarily blocked several challenged provisions of the DEI EOs. 

What Happened: A federal district judge in Maryland temporarily halted enforcement of provisions in DEI EOs that applied to private companies; however, the injunction was subsequently lifted.  

What it means for HR: The temporary injunction—and its reversal—adds uncertainty for employers navigating DEI compliance. HR teams should continue to closely monitor legal developments related to these executive orders and review company I&D policies to ensure they align with current enforcement standards while remaining adaptable to potential changes.

Checklist: I&D Program Compliance 

Feb. 25: “Making America Healthy Again by Empowering Patients with Clear, Accurate, and Actionable Health Care Pricing Information” (EO 14221) 

What Happened: This order aimed to hold group health plans and health insurance issuers accountable for adhering to the price transparency rules established during the first Trump administration.  

What It Means for HR: This EO underscores the importance of HR’s compliance with health care price transparency regulations.  

March 14: The 4th U.S. Circuit Court of Appeals lifted a nationwide injunction on the DEI EOs. 

What Happened: The 4th Circuit allowed the DEI EOs to be enforced while litigation continues. The three judges said that while these orders and accompanying actions could ultimately be deemed unconstitutional, the orders as written are not.  

What It Means for HR: The DEI EOs are back in effect, pending further litigation. 

Questionnaire: Does Your Organization’s I&D Strategy Align with SHRM’s BEAM Framework?

April 9: The Trump administration issued a memorandum ordering the repeal of what it called unlawful regulations.  

What Happened: The repeal named 10 Supreme Court decisions that would be used to determine lawfulness. Regulations found to be unlawful will be repealed under this order without notice and comment, when that procedure would be “impracticable, unnecessary, or contrary to the public interest.”  

What It Means for HR: This memo could lead to abrupt changes in regulations but also deregulation that frees up company resources from some compliance efforts. 

April 21: The grace period allowing federal contractors to comply with the existing Office of Federal Contract Compliance Programs affirmative action regulations ended.  

What Happened: Federal contractors can no longer implement affirmative action as used to be required by the federal government. 

What It Means for HR: HR departments within federal contracting organizations must now shift their focus from implementing affirmative action plans to ensuring nondiscrimination. However, HR professionals working for state contractors may have state obligations to provide affirmative action. 

On-Demand Webinar: 100 Days In: Policy Changes, Workforce Impact, and How HR Can Respond 

April 23: “Restoring Equality of Opportunity and Meritocracy”

What Happened: Trump called disparate-impact liability — a common ground for lawsuits under anti-discrimination laws — unlawful.

What It Means for HR: HR professionals could wind up seeing a dip in litigation against their employers. Liability may ebb as well.

April 30: The Trump administration marks the completion of its first 100 days in office.  

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